PRIVACY POLICY

 

Index

Introduction and overview

This privacy policy has been written (version 29.03.2023-112453619) in order to explain to you, in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors (e.g. providers) commissioned by us – process, will process in the future and what lawful options you have. The terms we use are gender neutral.

In short: We inform you comprehensively about any data we process about you.

Privacy policies usually sound very technical and involve legal jargon. This privacy statement is intended to describe the most important things to you as simply and transparently as possible. As far as it is conducive to transparency, technical terms are explained in a reader-friendly manner. In this way, we inform you in clear and simple language that we only process personal data during our business activities if there is a corresponding legal basis.

Area of application

This data protection declaration applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (order processors). By personal data, we mean information within the meaning of Art. 4 No. 1 DSGVO, such as a person’s name, email address and postal address. The scope of this privacy policy includes:

– All online presences (websites) that we operate;

– Social media presences and email communication;

– Mobile apps for smartphones and other devices.

In short: This privacy policy applies to all areas in which personal data is processed in the company via the described channels in a structured manner. If we enter legal relationships with you outside of these channels, we will inform you separately where applicable.

Legal basis

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

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

Further conditions such as the perception of recordings in the public interest and the exercise of public authority as well as the protection of vital interests do not generally occur with us. If such a legal basis should be relevant, it will be indicated at the appropriate place.

In addition to the EU-Regulation, national laws also apply:

– in Austria, this is the Federal Act on the Protection of Individuals regarding the Processing of Personal Data (Data Protection Act), or DSG for short.

– in Germany, the Federal Data Protection Act, or BDSG for short, applies.

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

Contact details of the responsible person

If you have any questions about data protection or the processing of personal data, do not hesitate to contact us:

S-Quad Handels- und Beteiligungs GmbH

Mr. Michael Radner, General Counsel

Goldschmiedgasse 2/6.5

1010 Vienna, Austria

E-Mail: mr@s-fo.at, office@schuetz-familyoffice.com

Imprint: https://www.s-fo.at/imprint

Duration of storage

It is our general criterion that we only store personal data to the extent and for as long as is absolutely necessary for us. This means that we delete personal data as soon as the reason for processing the data no longer exists.

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

Rights under the General Data Protection Regulation

Pursuant to Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

  • – According to Article 15 DSGVO, you have a right of access to whether we process data about you. If this is the case, you have the right to receive a copy of the data and the following information:
    • o the purpose for which we carry out the processing;
    • o the categories, i.e. the types of data that are processed;
    • o who receives this data and, if the data is transferred to third countries, how security can be guaranteed;
    • o how long the data will be stored;
    • o the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • o that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • o the origin of the data if we have not collected it from you;
    • o whether profiling is carried out, i.e. whether data is automatically analysed to arrive at a personal profile of you.
  • – You have a right to rectification of data under Article 16 of the GDPR, which means that we must rectify data if you find errors.
  • – You have the right to erasure (“right to be forgotten”) under Article 17 of the GDPR, which specifically means that you can ask for your data to be deleted.
  • – According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it any further.
  • – According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a common format upon request.
  • – According to Article 21 of the GDPR, you have a right to object, which, once enforced, entails a change in processing.

    • o If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
    • o If data is used to carry out direct advertising, you can object to this type of data processing at any time. We may then no longer use your data for direct marketing.
    • o If data is used for profiling, you can object to this type of data processing at any time. We may no longer use your data for profiling after this.
  • – You may have the right under Article 22 of the GDPR not to be subject to a decision based solely on automated processing (for example profiling).
  • – You have the right to complain under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

Austria Data Protection Authority

Head: Dr. Andrea Jelinek, M.D.

Address: Barichgasse 40-42, 1030 Vienna

Telephone no.: +43 1 52 152-0

E-Mail: dsb@dsb.gv.at
Website: https://www.dsb.gv.at/

Cookies

Our website uses HTTP cookies to store user-specific data.

Below we explain what cookies are and why they are used so that you can better understand the following privacy policy.

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

One thing cannot be denied: Cookies are really useful little helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are also other cookies for other applications. HTTP cookies are small files that are stored on your computer by our website. These cookie files are automatically placed in the cookie folder, effectively the “brain” of your browser. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified.

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

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

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

For example, this is what cookie data can look like:

Name: _ga

Wert: GA1.2.1326744211.152112453619-9

Intended use: Distinction of website visitors

Expiry date: after 2 years

A browser should be able to support these minimum sizes

– At least 4096 bytes per cookie

– At least 50 cookies per domain

– At least 3000 cookies in total

What types of cookies are there?

The question of which cookies we use depends on the services used and is clarified in the following sections of the privacy policy.

We can distinguish between 4 types of cookies:

Essential cookies

These cookies are necessary to ensure basic website functionality.

Purpose cookies

These cookies collect information about user behaviour and whether the user receives any error messages. In addition, these cookies are also used to measure the loading time and the behaviour of the website with different browsers.

Goal-oriented cookies

These cookies provide a better user experience. For example, locations entered, font sizes or form data are saved.

Advertising cookies

These cookies are also called targeting cookies. They are used to provide the user with individually adapted advertising.

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

Purpose of processing via cookies

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

What data is processed?

Cookies are small helpers for many different tasks. Unfortunately, it is not possible to generalise what data is stored in cookies.

Storage period of cookies

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

You can also influence the storage period yourself. You can delete all cookies manually at any time via your browser. Furthermore, cookies that are based on consent will be deleted at the latest after revocation of your consent, whereby the legality of the storage remains unaffected until then.

Right of objection – how can I delete cookies?

You decide how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of deleting, deactivating or only partially permitting cookies. For example, you can block third-party cookies but allow all other cookies.

Legal basis

The so-called “Cookie Guidelines” have been in place since 2009. These state that the storage of cookies requires your consent (Article 6 para. 1 lit. a DSGVO). Within the EU countries, however, there are still very different reactions to these directives. In Austria, this directive was implemented in § 96 para. 3 of the Telecommunications Act (TKG). In Germany, the Cookie Directive has not been implemented as national law. Instead, this directive was largely implemented in § 15 para.3 of the Telemedia Act (TMG).

For cookies that are absolutely necessary, even if there is no consent, there are legitimate interests (Article 6 para. 1 lit. f DSGVO), which in most cases are of an economic nature. We want to provide visitors to the website with a pleasant user experience and for this purpose certain cookies are often absolutely necessary.

Where cookies are used that are not strictly necessary, this is only done with your consent. The legal basis in this respect is Art. 6 para. 1 lit. a DSGVO.

In the following sections, you will be informed in more detail about the use of cookies, insofar as the software used uses cookies.

If you have any questions, please do not hesitate to contact the above mentioned responsible person.

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