Firmensitz von EFS Consulting, ein Bauwerk im Auftrag von Max Fabiani im 3. Wiener Gemeindebezirk, Landstraße

Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement 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 services”).

The terms used are not gender specific.

Last Update: 17. Oktober 2024

Preamble
Controller
Contact information of the Data Protection Officer
Overview of processing operations
Relevant legal bases
Security Precautions
Transmission of Personal Data
International data transfers
Erasure of data
Rights of Data Subjects
Business services
Providers and services used in the course of business
Provision of online services and web hosting
Use of Cookies
Contact and Inquiry Management
Video Conferences, Online Meetings, Webinars and Screen-Sharing
Audio Content
Job Application Process
Cloud Services
Newsletter and Electronic Communications
Sweepstakes and Contests
Surveys and Questionnaires
Web Analysis, Monitoring and Optimization
Online Marketing
Profiles in Social Networks (Social Media)
Plugins and embedded functions and content
Management, Organization and Utilities
Changes and Updates to the Privacy Policy
Terminology and Definitions

Controller

Responsible Party

EFS Unternehmensberatung GesmbH
Ungargasse 59-61
1030 Vienna

E-mail address: office@efs.at

Legal Notice:

https://efs.consulting/en/imprint

https://framechangers.at/impressum

http://www.efs-utility.com/impressum

Contact information of the Data Protection Officer

datenschutz@efs.at

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Purposes of Processing

Provision of contractual services and fulfillment of contractual obligations.
Contact requests and communication.
Security measures.
Direct marketing.
Web Analytics.
Targeting.
Office and organisational procedures.
Conversion tracking.
Clicktracking.
Affiliate Tracking.
Managing and responding to inquiries.
Job Application Process.
Conducting sweepstakes and contests.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and usability.
Information technology infrastructure.

Relevant legal bases

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR) – If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Austria. This includes in particular the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). In particular, the Data Protection Act contains special provisions on the right of access, rectification or cancellation, processing of special categories of personal data, processing for other purposes and transmission and automated decision making in individual cases.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with 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 securely and encryptedly transmitted.

Transmission of Personal Data

While processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.

Data Transfer within the Organization: Data Transfer within the Corporate Group: We may transfer personal data to other companies within our corporate group or grant them access to it. If the data is shared for administrative purposes, it is based on our legitimate business and commercial interests or occurs if necessary to fulfil our contractual obligations, or when consent from the individuals concerned has been obtained or a legal permission exists.

International data transfers

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 the processing is done within the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is only done in accordance with legal requirements. If the data protection level in the third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from individual third-country providers, with adequacy decisions primarily serving as the foundation. “Information regarding third-country transfers and existing adequacy decisions can be obtained from the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure within the adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/s/. We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.

Rights of Data Subjects

Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right of withdrawal for consents: You have the right to revoke consents at any time.
Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, 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 process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as 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 disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Prospective customers; Business and contractual partners; Customers.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact requests and communication; Office and organisational procedures; Managing and responding to inquiries; Conversion tracking (Measurement of the effectiveness of marketing activities). Profiles with user-related information (Creating user profiles).
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Economic Analyses and Market Research: For economic reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the persons concerned may include contractual partners, interested parties, customers, visitors and users of our online service.The analyses are carried out for the purpose of business evaluations, marketing and market research (for example, to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and if possible anonymously (e.g. as summarized data); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and client relationship.Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts, subcontractors or in the field of IT, office or comparable services, taking into account the professional requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Providers and services used in the course of business

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”) in compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management of our business operations and internal organization.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Customers; Prospective customers; Users (e.g. website visitors, users of online services); Business and contractual partners. Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Direct marketing (e.g. by e-mail or postal). Web Analytics (e.g. access statistics, recognition of returning visitors).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider.

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status). Content data (e.g. text input, photographs, videos).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).). Security measures.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Collection of Access Data and Log Files: The access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Content-Delivery-Network: We use a so-called “Content Delivery Network” (CDN). A CDN is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Telekom Magenta Business: Cloud storage service; Service provider: T-Mobile Austria GmbH, Rennweg 97-99, A-1030 Wien, Österreich; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://cloud.telekom-dienste.de/; Privacy Policy: https://www.telekom.de/datenschutz-ganz-einfach.

Use of Cookies

Cookies are small text files or other types of storage markers that store information on end devices and read information from them. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used of an online offer. Furthermore, cookies can be used for various concerns, such as for the functionality, security, and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on Consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless it is not required by law. Permission is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service (i.e., our online offer) expressly requested by the users. The revocable consent is clearly communicated to them and contains information on the respective cookie usage.

Notes on the legal basis for data protection: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are based on our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or, if this occurs within the fulfillment of our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used by us in the course of this data protection declaration or within the scope of our consent and processing processes.

Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:

Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a site. Similarly, user data collected via cookies can be used for reach measurement. Unless we provide users with explicit information about the nature and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users’ consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users’ devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device. If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
Usercentrics: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing; Service provider: Usercentrics GmbH, Sendlinger Strasse 7, 80331 Munich, Germany; Website: https://usercentrics.com/; Privacy Policy: https://usercentrics.com/privacy-policy/.

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; Direct marketing (e.g. by e-mail or postal). Web Analytics (e.g. access statistics, recognition of returning visitors).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

Contact form: When users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider.

Video Conferences, Online Meetings, Webinars and Screen-Sharing

We use platforms and applications of other providers (hereinafter referred to as “Conference Platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “Conference”). When using the Conference Platforms and their services, we comply with the legal requirements.

Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.

Logging and recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked – if necessary – for their consent.

Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Persons depicted.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact requests and communication. Office and organisational procedures.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Microsoft Teams: Conference and communication software; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: EEA – Data Privacy Framework (DPF)
Zoom: Conference and communication software; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Data Processing Agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA). Basis for third-country transfers: EEA – Data Privacy Framework (DPF).

Audio Content

We use hosting and analysis services of service providers to offer our audio content for listening to or downloading and to obtain statistical information on the request of the audio content.

Processed data types: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Provision of our online services and usability. Conversion tracking (Measurement of the effectiveness of marketing activities).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Buzzsprout: Podcast hosting and statistical analysis of podcast performance; Service provider: Buzzsprout, 5133 San Jose Blvd., Jacksonville, FL 32207, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.buzzsprout.com. Privacy Policy: https://www.buzzsprout.com/privacy.
Spotify: Spotify – Music hosting and Widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://podcasters.spotify.com/; Privacy Policy: https://www.spotify.com/legal/privacy-policy/.
Apple Podcasts: Podcast hosting and statistical analysis of podcast performance; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.apple.com/apple-podcasts/. Privacy Policy: https://www.apple.com/legal/privacy/.

Job Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information contained therein.

In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.

If made available, applicants can submit their applications via an online form. The data will be transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and the reception on our server. For the purposes of searching for applicants, submitting applications and selecting applicants, we may make use of the applicant management and recruitment software, platforms and services of third-party providers in compliance with legal requirements. Applicants are welcome to contact us about how to submit their application or send it to us by regular mail.

Processing of special categories of data: To the extent that special categories of personal data (Article 9(1) GDPR, e.g., health data, such as disability status or ethnic origin) are requested from applicants or communicated by them during the application process, their processing is carried out so that the controller or the data subject can exercise rights arising from employment law and the law of social security and social protection, in the case of protection of vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for the assessment of the employee’s work ability, for medical diagnosis, for the provision or treatment in the health or social sector, or for the management of systems and services in the health or social sector.

Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Admission to a talent pool – Admission to a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

Duration of data retention in the applicant pool in months: 6 months

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos). Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
Data subjects: Job applicants.
Purposes of processing: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship).
Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR).

Cloud Services

We use Internet-accessible software services (so-called “cloud services”, also referred to as “Software as a Service”) provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users’ devices for web analysis or to remember user settings (e.g. in the case of media control).

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Customers; Employees (e.g. Employees, job applicants); Prospective customers. Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).).
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Microsoft Cloud Services: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).

Newsletter and Electronic Communications

We send newsletters, e-mails and other electronic communications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.

Double opt-in procedure: The registration to our newsletter via the website takes place in general in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with external e-mail addresses.

The registrations for the newsletter are logged to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise, the changes of your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blocklist.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions and offers.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
Purposes of processing: Direct marketing (e.g. by e-mail or postal); Web Analytics (e.g. access statistics, recognition of returning visitors). Provision of contractual services and fulfillment of contractual obligations.
Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing methods, procedures and services used:

Measurement of opening rates and click rates: The newsletters contain a so-called “web beacon”, which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
Prerequisite for the use of free services: Consent to the sending of mailings can be made dependent on the use of free services (e.g. access to certain content or participation in certain campaigns) as a prerequisite. If the users would like to take advantage of the free service without registering for the newsletter, we offer them to contact us.
Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider.

Sweepstakes and Contests

We process personal data of participants in competitions, contents, raffles, prize-draws or sweepstakes (hereinafter referred to as “competitions”) only in compliance with the relevant data protection regulations and if the processing is contractually necessary for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse by possible recording of IP addresses when submitting entries to the competition.

In the event that entries are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries, or the winner or reporting on the competition), we would like to point out that the names of participants may also be published in this context. The participants can object to this at any time.

If the competitions take place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective online platforms also apply. In such cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that we must be contacted with regard to the competitions.

The data of the participants will be deleted as soon as the competition has ended and the data is no longer required to inform the winners or because questions about the competition can be expected. In general, the data of the participants will be deleted at the latest 6 months after the end of the competition. Winners’ data can be retained for a longer period of time, e.g. in order to answer questions about the prizes or to fulfil the prizes; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of coverage of the competition in online and offline media.

Insofar as data was collected for other purposes as part of the competition, its processing and storage period shall be governed by the privacy information for this use (e.g. in the case of registration for a newsletter as part of a competition).

Processed data types: Inventory data (e.g. names, addresses); Content data (e.g. text input, photographs, videos). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Participants in sweepstakes and competitions.
Purposes of processing: Conducting sweepstakes and contests.
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Surveys and Questionnaires

We conduct surveys and interviews to gather information for the survey purpose communicated in each case. The surveys and questionnaires (“surveys”) carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user’s browser or to enable a resumption of the survey with the aid of a cookie).

Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Participants.
Purposes of processing: Feedback (e.g. collecting feedback via online form); Direct marketing (e.g. by e-mail or postal); Web Analytics (e.g. access statistics, recognition of returning visitors). Contact requests and communication.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider.
Microsoft Cloud Services: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).
Microsoft Teams: Microsoft Teams – Messenger; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy Policy: https://privacy.microsoft.com/en-GB/privacystatement, Security information: https://www.microsoft.com/en-GB/trust-center. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).

Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour or interests of users, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited 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 agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called “cookies”) or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited 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 or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Processed data types: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (Creating user profiles).
Security measures: IP Masking (Pseudonymization of the IP address).
Legal Basis: Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

Matomo: This service is used exclusively under the domain efs.consulting and framechangers.at. This service is not used under the domain www.efs-utility.com. Matomo is software that is used for the purposes of web analysis and reach measurement. As part of the use of Matomo, cookies are generated and stored on the user’s terminal device. User data collected through the use of Matomo is processed only by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal Basis: Consent (Article 6 (1) (a) GDPR). Retention period: The cookies have a maximum storage period of 13 months.
Matomo Tag Manager: This service is used exclusively under the domain framechangers.at. This service is not used under the domain efs.consulting and www.efs-utility.com. Matomo Tag Manager is a central management tool that integrates third-party tracking tags (such as LinkedIn Insight Tag) into the website without cookies being set by Matomo Tag Manager or personal data being processed. The use of third-party tags is generally based on the consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) of the data subject. User data collected through the use of Matomo is processed only by us and is not shared with third parties; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Matomo Tag Manager: Tool for managing third-party tags; Service provider: InnoCraft Limited (InnoCraft, we), 7 Waterloo Quay, PO625, 6140 Wellington, New Zealand. Website: https://matomo.org/ Privacy Policy: https://matomo.org/privacy-policy/

Online Marketing

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 the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Processed data types: Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Event Data (Facebook) (“Event Data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences). Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles); Provision of our online services and usability. Clicktracking.
Security measures: IP Masking (Pseudonymization of the IP address).
Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Opt-Out: We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called “opt-out”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.

Further information on processing methods, procedures and services used:

Meta Pixel and Custom Audiences (Custom Audiences): This service is used exclusively under the domain framechangers.at. This service is not used under the domain efs.consulting and www.efs-utility.com. With the help of the Meta-Pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other software in apps), Meta is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called “Meta ads”). Accordingly, we use Meta-Pixels to display Meta ads placed by us only to Meta users and within the services of partners cooperating with Meta (so-called “audience network” https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Meta (so-called “custom audiences”). With the help of Meta-Pixels, we also want to ensure that our Meta ads correspond to the potential interest of users and do not appear annoying. The Meta-Pixel also enables us to track the effectiveness of Meta ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Meta ad (known as “conversion tracking”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: EEA – Data Privacy Framework (DPF). Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Google Ad Manager: This service is used exclusively under the domain framechangers.at. This service is not used under the domain efs.consulting and www.efs-utility.com. We use the service “Google Ad Manager” to place ads in the Google advertising network (e.g. in search results, videos, websites, etc.). The Google Ad Manager stands out because ads are displayed in real time based on users’ presumed interests. This allows us to display ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest, and measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/; Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms. where Google acts as processor, Data Processing Conditions for Google Advertising Products and standard contractual clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms apply.
Google Ads and Conversion Tracking: This service is used exclusively under the domain framechangers.at. This service is not used under the domain efs.consulting and www.efs-utility.com. Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
LinkedIn Insights Tag: This service is used exclusively under the domain framechangers.at. This service is not used under the domain efs.consulting and www.efs-utility.com. Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions, as well as stores it in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar target groups); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, cookie policy: https://www.linkedin.com/legal/cookie_policy; Data Processing Agreement: https://www.linkedin.com/legal/l/dpa; Basis for third-country transfers: EEA – Data Privacy Framework (DPF). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
UTM Parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the “UTM” parameter. For example, a UTM parameter “utm_source=platformX &utm_medium=video” can tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information, we can, for example, check our visibility on the Internet or the effectiveness of our campaigns; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Google Tag Manager: We utilise the Google Tag Manager, a tool by Google, to manage website tags via a central user interface. Tags are small code elements on our website that serve, among other things, to measure and analyse visitor activities. This technology assists us in improving our website and the services offered on it.The Google Tag Manager itself does not create user profiles, store cookies, or perform any independent analyses. It is solely used to integrate the tools and services we use for our website more simply and efficiently. However, when using the Google Tag Manager, users’ IP addresses are transmitted to Google, which is technically necessary to execute the various services we utilise.It is important to note that this data processing only occurs when services are integrated through the Tag Manager that require it. For details on these services and how they process data, we refer you to the subsequent sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).
Google Tag Manager (server-side use): Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online services (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, neither user profiles nor cookies are stored. The integration of the other services is server-based. This means that the users’ data is not transmitted directly from their end device to the respective service. In particular, the IP address of the users is not transmitted to the other service or Google. Instead, the data is first transmitted to our server, where the user’s data records are assigned to our internal user identification number. Subsequent transmission takes place only in this pseudonymized form from our server to the servers of the respective service providers. The identification number does not contain any unique data, such as names or e-mail addresses; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF). Further Information: https://business.safety.google/adsservices/ (Types of processing and data processed).

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form). Marketing.
Legal Basis: Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).
Facebook Pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF); Further Information: We are jointly responsible (so called “joint controller”) with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see “Things that you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information. see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information?” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook (“Information about Page-Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited.
LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF); Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further Information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors for the purposes of creating „Page-Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from the users’ profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy
We have concluded a special agreement with LinkedIn Irland, the ‘Page Insights Joint Controller Addendum (the ‘Addendum’)’ (https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and wherein LinkedIn has agreed to fulfill the rights of the affected parties (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of the users (in particular to access to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, particularly regarding the transmission of data to the parent company LinkedIn Corporation in the USA.
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF). Opt-Out: https://myadcenter.google.com/personalizationoff.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers). Content data (e.g. text input, photographs, videos).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and usability.
Legal Basis: Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

YouTube videos: This service is used exclusively under the domain efs.consulting and framechangers.at. This service is not used under the domain www.efs-utility.com. Video contents; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF). Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
Buzzsprout: This service is used exclusively under the domain efs.consulting and framechangers.at. This service is not used under the domain www.efs-utility.com. Podcast-Hosting und statistische Analyse der Podcastabrufe; Dienstanbieter: Buzzsprout, 5133 San Jose Blvd., Jacksonville, FL 32207, USA; Rechtsgrundlagen: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO); Website: https://www.buzzsprout.com. Datenschutzerklärung: https://www.buzzsprout.com/privacy.

This service is used exclusively under the domain efs.consulting and framechangers.at. This service is not used under the domain www.efs-utility.com.

Management, Organization and Utilities

We use services, platforms and software from other providers (hereinafter referred to as ” third-party providers”) for the purposes of organizing, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

Processed data types: Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organisational procedures.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

Affiliate Tracking: Custom Audiences refers to the process of determining target groups for advertising purposes, e.g. the display of advertisements. For example, a user’s interest in certain products or topics on the Internet may be used to conclude that the user is interested in advertisements for similar products or the online store in which the user viewed the products. “Lookalike Audiences” is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are typically used.
Clicktracking: Clicktracking allows users to keep track of their movements within an entire website. Since the results of these tests are more accurate if the interaction of the users can be followed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes.
Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
Personal Data: “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.
Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Targeting: “Tracking” is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.

Privacy Policy

Preamble

Table of contents

Controller

Contact information of the Data Protection Officer

Overview of processing operations

Categories of Processed Data

Categories of Data Subjects

Purposes of Processing

Relevant legal bases

Security Precautions

Transmission of Personal Data

International data transfers

Erasure of data

Rights of Data Subjects

Business services

Providers and services used in the course of business

Provision of online services and web hosting

Use of Cookies

Contact and Inquiry Management

Video Conferences, Online Meetings, Webinars and Screen-Sharing

Audio Content

Job Application Process

Cloud Services

Newsletter and Electronic Communications

Sweepstakes and Contests

Surveys and Questionnaires

Web Analysis, Monitoring and Optimization

Online Marketing

Profiles in Social Networks (Social Media)

Plugins and embedded functions and content

Management, Organization and Utilities

Changes and Updates to the Privacy Policy

Terminology and Definitions