Privacy policy

1. Introduction

We take the protection of the data of the users of our website and/or our mobile app very seriously and undertake to protect the information that users provide to us in connection with the use of our website and/or our mobile app (together: "digital assets"). Furthermore, we undertake to protect and use your data in accordance with applicable law.

This privacy policy explains our practices with regard to the collection, use and disclosure of your data through the use of our digital assets when you access the services via your devices.

Please read the privacy policy carefully and make sure that you fully understand our practices with regard to your data before you use our services. If you have read this policy, fully understood it and do not agree with our approach, you must stop using our digital assets and services. By using our services you acknowledge the terms of this privacy policy. Continued use of the services constitutes your consent to this privacy policy and to any changes to it.

In this privacy policy you will learn about:

• How we collect data
• What data we collect
• Why we collect this data
• Who we share the data with
• Where the data is stored
• How long the data is retained
• How we protect the data
• How we deal with minors
• Updates or changes to the privacy policy

What data do we collect?

Below you will find an overview of the data we may collect:

Unidentified and unidentifiable information that you provide during the registration process or that is collected through your use of our services ("non-personal data"). Non-personal data does not allow any conclusions to be drawn about who it was collected from. The non-personal data we collect consists mainly of technical and aggregated usage information.

Individually identifiable information, i.e. all information through which you can be identified or could reasonably be identified ("personal data"). The personal data we collect via our services may include information that is requested from time to time, such as names, e-mail addresses, addresses, telephone numbers, IP addresses and more. Where we combine personal data with non-personal data, we treat this as personal data for as long as it is combined.

How do we collect data?

Below are the main methods we use to collect data:

We collect data when you use our services. In other words, when you visit our digital assets and use our services, we may collect, capture and store usage, session and associated information.

We collect data that you provide to us directly, for example when you contact us directly via a communication channel (e.g. an e-mail with a comment or feedback).

We may collect data from third-party sources, as described below.

We collect data that you provide to us when you sign in to our services via a third party such as Facebook or Google.

Why do we collect this data?

We may use your data for the following purposes:

to provide and operate our services;

to develop, adapt and improve our services;

to respond to your feedback, enquiries and requests and to offer assistance;

to analyse demand and usage patterns;

for other internal, statistical and research purposes;

to improve our ability to ensure data security and prevent fraud;

to investigate violations and to enforce our terms and policies, and to comply with applicable law, regulations or official orders;

to send you updates, news, advertising material and other information relating to our services. In the case of advertising e-mails, you can decide for yourself whether you would like to continue receiving them. If not, simply click the unsubscribe link in those e-mails.

Who do we share the data with?

We may share your data with our service providers in order to operate our services (e.g. storage of data via third-party hosting services, provision of technical support, etc.).

We may also disclose your data in the following circumstances:

(i) to investigate, detect, prevent or address unlawful activities or other misconduct;

(ii) to establish or exercise our rights of defence;

(iii) to protect our rights, our property or our personal safety, as well as the safety of our users or the public;

(iv) in the event of a change of control of us or of any of our affiliated companies (by way of a merger, acquisition or purchase (in substance) of all assets, amongst other things);

(v) to collect, hold and/or manage your data using authorised third parties (e.g. cloud service providers), insofar as this is appropriate for business purposes;

(vi) to work jointly with third parties in order to improve your user experience. In order to avoid misunderstandings, we would like to point out that we may transmit or share non-personal data to third parties at our own discretion, or otherwise use them.

Please note that our services enable social interactions (e.g. posting content, information and comments publicly and chatting with other users). We point out that any content or data that you make available in these areas may be read, captured and used by other people. We advise against posting or sharing information that you do not want to make public. If you upload content to our digital assets or otherwise make it available in the course of using a service, you do so at your own risk. We cannot control the actions of other users or members of the public who have access to your data or content. You acknowledge and confirm hereby that copies of your data may remain retrievable even after it has been deleted, on cached and archived pages or after a copy of your content has been created or stored by third parties.

Cookies and similar technologies

When you visit or access our services, we authorise third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services ("tracking technologies"). These tracking technologies may enable third parties to collect your data automatically in order to improve the browsing experience on our digital assets, to optimise their performance and to ensure a tailored user experience, as well as for security and fraud prevention purposes.

To find out more about this, please read our cookie policy.

We may provide advertising through our services and our digital assets (including websites and applications that use our services) which may also be tailored to you, e.g. advertisements based on your most recent browsing behaviour on websites, devices or browsers.

In order to provide these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including transparent GIFs) and/or HTML5 Local Storage and/or other technologies. We may also use third parties such as network advertisers (i.e. third parties that display advertisements based on your website visits) in order to serve targeted advertisements. External ad network providers, ad publishers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including transparent GIFs) and/or Flash cookies and/or other technologies in order to measure the effectiveness of their advertisements and to tailor advertising content for you. These third-party cookies and other technologies are subject to the specific privacy policy of the respective third party and not to this one.

Where do we store the data?

Non-personal data

Please note that our companies, as well as our trusted partners and service providers, are located all over the world. For the purposes explained in this privacy policy, we therefore store and process all the non-personal data we collect in different legal jurisdictions.

Personal data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and, insofar as necessary for the proper provision of our services and/or required by law (as further explained below), in other legal jurisdictions.

How long is the data retained?

Please note that we retain the data collected for as long as is necessary to provide our services, to meet our legal and contractual obligations towards you, to settle disputes and to enforce our agreements.

We may at any time correct, supplement or delete inaccurate or incomplete data at our own discretion.

How do we protect the data?

The hosting service for our digital assets provides us with the online platform through which we can offer our services to you. Your data may therefore be stored via the data storage, databases and general applications of our hosting provider. It stores your data on secure servers behind a firewall and it offers secure HTTPS access to most areas of its services.

All payment options offered by us and by our hosting provider for our digital assets comply with the requirements of the PCI-DSS (Payment Card Industry Data Security Standard) of the PCI Security Standards Council. This involves collaboration between brands such as Visa, MasterCard, American Express and Discover. The PCI-DSS requirements help to ensure the secure handling of credit card data (including physical, electronic and procedural measures) by our shop and the service providers.

Notwithstanding the measures and efforts taken by us and by our hosting provider, we cannot and will not guarantee absolute protection and absolute security of the data that you upload, publish or otherwise share with us or others.

For this reason, we ask you to set secure passwords and, where possible, not to transmit any confidential information to us or to others whose disclosure would, in your opinion, cause you significant or lasting harm. Since e-mail and instant messaging are not considered secure forms of communication, we also ask you not to share any confidential information via either of these communication channels.

How do we deal with minors?

The services are not intended for users who have not yet reached the legal age of majority. We will not knowingly collect data from children. If you are not yet of legal age, you should not download or use the services or provide us with any information.

We reserve the right to request proof of age at any time, so that we can verify whether minors are using our services. In the event that we become aware that a minor is using our services, we may deny these users access to our services and block them, and we may delete all data stored by us about this user. If you have reason to believe that a minor has provided data to us, please contact us as explained below.

What we use your personal data for

We use your personal data only for the purposes set out in the privacy policy and only where we are convinced that:

the use of your personal data is necessary to perform or conclude a contract (e.g. in order to provide you with the services themselves or with customer service or technical support);

the use of your personal data is necessary in order to comply with the relevant legal or official obligations, or

the use of your personal data is necessary in order to support our legitimate business interests (provided that this is always done in a manner that is proportionate and that respects your data protection rights).

Your rights

If you are resident in the EU, you may:

request confirmation as to whether personal data that concerns you is being processed, and request access to your stored personal data and to certain additional information;

request receipt of the personal data you have provided to us in a structured, commonly used and machine-readable format;

request the correction of the personal data stored with us;

request the erasure of your personal data;

object to the processing of your personal data by us;

request the restriction of the processing of your personal data, or

lodge a complaint with a supervisory authority.

International data transfers

Please note, however, that these rights are not unconditionally valid and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data collected by us and its use, please contact us as set out below.

In the course of providing the services, we may transfer data across borders to affiliated companies or other third parties and from your country/legal jurisdiction to other countries/legal jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA where we are convinced that an appropriate or comparable level of protection of personal data exists. We will take appropriate steps to ensure that we have appropriate contractual agreements in place with our third parties so that appropriate safeguards are in place to minimise the risk of unlawful use, alteration, deletion, loss or theft of your personal data and so that these third parties act at all times in accordance with the applicable laws.

Rights under the California Consumer Privacy Act

If you use the services as a resident of California, you may be entitled under the California Consumer Privacy Act ("CCPA") to request access to and erasure of your data.

To exercise your right of access to and erasure of your data, please read below how you can contact us.

We do not sell the personal data of users for the purposes and intents of the CCPA.

Users of the services who are resident in California and under 18 years of age may request via e-mail at the address given in the "Contact" section below that their published content be removed and deleted. All such requests must be marked "California Removal Request". All requests must include a description of the content whose deletion you wish to have, as well as sufficient information to allow us to locate the material. We do not accept notices that are not marked or not properly submitted, and we may be unable to respond if you do not provide sufficient information. Please note that your request does not ensure that the material will be completely or comprehensively deleted. Material published by you may, for example, be republished or reposted by other users or third parties.

Updates or changes to the privacy policy

We may revise this privacy policy from time to time at our own discretion; the version published on the website is always the current one (see the "as of" note). We ask you to check this privacy policy regularly for changes. In the event of material changes, we will publish a notice about them on our website. If you continue to use our website after being notified of changes, this is deemed your confirmation and consent to the changes to the privacy policy and your agreement to be bound by the terms of those changes.

Contact

If you have general questions about the services or about the data we collect about you and its use, please contact us at:

Name: Michael Mutschlechner

Address: on request, as this is a private address

E-mail address: info@projekt-freespirit.net