Privacy policy

1 Introduction

1.1 This Privacy Policy of A2A Holding GmbH ("Policy") describes how A2A Holding, Getreidegasse 47, Top 15, 5020 Salzburg, Austria collects and processes personal data about you when you visit our website ("Website"), and how we use it. We process your data exclusively on the basis of the legal provisions (DSGVO, DSG 2018, TKG 2003).

2 Data collected by us

2.1 Data you share with us. When you visit our website, correspond with us, or participate in one of our promotions, participate in our surveys, post on our websites, subscribe to our newsletters, purchase our goods, create an account, or when you communicate with or with us through one of our social media platforms, such as our chatbot tools, you may be sharing data about yourself with us. This may include data that allows us to draw conclusions about you ("personal data"). If we ask you to provide certain data, we collect that data which is contained in the respective forms or on the corresponding pages. In addition, you can provide us with further information at your own request when you contact us or interact with us in any other way.

2.2 If you are a regular visitor to our website, you may choose to set up a user account ("User Account") with us. The information you give us when you create a User Account includes, but is not limited to, your name, account username, email address, country of residence, phone number. When you register to have a user account with us, you also create a unique password that allows you to access your account. We also collect data regarding your favorite content on our websites (such as videos you like).

2.3 If you decide to purchase goods or services on our website, we also collect your delivery address, billing address and payment details. Please note that your payment data is not stored by us; this is done by an external payment service provider.

2.4 If you choose to subscribe to one of our newsletters or receive other types of direct communication from us, you may provide us with your name, email address, gender, date of birth and interests.

2.5 When you visit our website, we may use your personal data to improve your user experience through our recommendations designed specifically for you. This may include recommending certain content to you based on your search history or Facebook Likes or interests. We do not collect your username or password for Facebook, Twitter or Google+. However, we may collect certain information from these sites that indicates whether you have Facebook, Twitter or Google+ accounts. This information is used to access or mine certain data about you from your Facebook, Twitter or Google+ profiles in order to improve your user experience and provide you with content that is important to you. This is data that you post on your profile. We do not access your personal page settings.

2.7 Data collected automatically. When you visit our website or, we may automatically collect the following data: Your IP address, log-in data, location, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit, including the URL clickstream (sequence of page views) to, through and from our website, your ID for advertising purposes (if supported by your device, such as an Apple or Google product), products you viewed or searched for, videos you opened, download errors, duration of visits to specific pages and interactions between pages and apps, media download for offline use, screen resolution, device processing and storage capacity, playback errors and buffering issues, user behavior, such as duration of app use, and device IDs (for example, an IMEI address (an identification number assigned to cell phones that is used by GSM networks to enable them to recognize valid mobile devices). Automatic data collection is done through the use of various technologies, including "cookies" and "web beacons".

2.9 Data we receive from other sources. We may receive data about you from other sources when you use one of the other services (e.g., payment service providers) We also work closely with third parties (including, for example, business partners, technical services subcontractors, payment services and delivery services, advertising networks, analytics service providers, search engine operators, credit reporting agencies) and may receive data about you from them (including publicly available data).

3 Why we use your data

3.1 We use the data we collect to provide you with the best possible user experience when you visit our website or use our apps and connect with us, including by using our services and products. This includes the use of your data for the following purposes:

  • (a) Providing and Improving Our Products and Services: We use your information to provide you with the products and services you have requested through the Site, including when you make purchases, when we send you a confirmation email, or when we contact you about your account. We use your information to improve and customize our website, products and services to better match the behavior and technical capabilities of our users.
  • (b) Establishing and Managing Your Account: We use your information to set up your account and manage our relationship with you. We also use your information to communicate with you regarding your account and our Services.
  • (c) Administration of the Website and Apps: We use your information to administer our Website and Apps for internal operations, including for troubleshooting purposes, and to better understand errors you may experience when using our Website and Apps.
  • (d) Improve the use and content of our sites and apps: We use your data to improve the content of our sites and apps and to ensure that the content is presented as effectively as possible for you and your end devices.
  • (e) Protection and Security. We use data collected on our Website and Apps as part of our efforts to provide protection and security for our Website and Apps and to better manage our IT systems. We use data collected through our security systems to provide better protection and security for the premises and visitors to our events.
  • (f) Marketing: We use your information to communicate with you and keep you informed about our and third parties' activities and events in which you may be interested, and to make suggestions and recommendations to you on our Website and the Apps about goods or services that may be of interest to you. You will receive this information from us via email (subject to your prior consent where required by law), individual communications on our websites, targeted advertisements on our website, as well as on external platforms, text messages, via social media or by telephone.
  • (g) Online Marketing: We use your information to measure and understand the effectiveness of the advertising we deliver to you and others, and to deliver relevant advertising to you. We also use your information when we communicate with you on social media to build and maintain our social media brand.
  • (h) Customization and User Experience Improvement: To the extent permitted by law, we may aggregate data from external sources, including social media sites, with data provided by you and collected by us, including data obtained with cookies and web beacons. We may use this data and the aggregated data to learn more about your preferences as our customer, to improve your user experience on our website and apps, and to provide you with information, content, and offers that are tailored to you.
  • (i) Enable a consistent experience across all devices and platforms: We will match the data we have collected from you and received from you on one device or platform with the data we have collected from you or received from you on other devices or platforms.
  • (j) Providing Customer Services and Handling Complaints and Inquiries: We may use your information to provide you with more efficient customer services and to handle your complaints or inquiries.
  • (k) Making Required Disclosures and Enforcing Law: We may use your information to make required disclosures in response to requests for information that we are required by law to make to law enforcement, regulatory, or supervisory authorities, or in the defense of legal claims, and to enforce our Terms and Conditions and/or this Policy.
  • (l) effecting any sale, transfer or reorganization of any of our business units.

4 Legal basis for the use of your data

4.1 The processing of your personal data is based on a broad legal basis, including:

  • (a) When you have given your consent: for example, we need your consent to process your personal data for direct marketing activities, when we use cookie technologies, or when we process special categories of personal data, such as your clothing style.
  • (b) When the processing is necessary for the performance of a contract: for example, to deliver goods you have ordered from our online store or to enable an in-app purchase,
  • (c) When we must comply with a legal obligation: for example, we must disclose your information to a law enforcement agency or to your or our agents representing us in litigation.
  • (d) Where the processing is necessary on the basis of our legitimate interests; these include, but are not limited to. for example: (1) providing our products and services to you, (2) ensuring that your account is appropriately protected and our website, apps, network and information technology are secure and used properly, (3) better understanding how you use our products, services, apps and website and making improvements, (4) researching and analyzing the products and services you want, (5) tailoring our content, marketing, advertising and offers to your particular interests, (6) maintaining a profile on traditional and social media, (7) communicating effectively and social analytics and content performance on social media, (8) security related to our business operations and those of our business partners, and monitoring of areas around our as well as in our business premises to protect our employees, customers, and the general public from misconduct or criminal acts, (9) developing and maintaining relationships with suppliers, partners, and other companies and dealing with individuals working for them, (10) maintaining knowledge of current market practices to ensure that we provide a service that is competitive and meets our customers' expectations, and (11) determining the effectiveness of advertising on our website, apps, and partner websites. In some states, this type of data processing requires appropriate consent. We will obtain your consent when we are legally required to do so.

5 Data sharing and disclosure

5.1 We may share your data with third parties for the purposes set out in this policy in section 3, including but not limited to external online platforms, social media platforms, entities that provide a service to us or act as our agents, this includes but is not limited to subcontractors (including their agents) and specialist consultants, advertising agencies, advertising networks, IT suppliers, database suppliers, backup and disaster recovery specialists, email providers and other service providers as necessary to improve our products and services.

5.2

  • (a) We share aggregated, anonymized, or otherwise non-personal data with advertising partners, ad networks, and social networks that need that data to serve selected relevant ads to you and others. We also use aggregated data to help advertisers reach the types of audiences they want to target.
  • (b) We use the personal data we have collected from you to help our advertising partners show their ads to a targeted audience and present our advertising messages to you, including through the Facebook Custom Audience tool and Google Customer Match. This means that you will be shown ads that are of greater interest to you based on the personal data we have collected from you, and
  • (c) We share those of your personal data and access data from analytics services and search engine providers that help us improve and optimize the Website and Apps to better tailor content and advertising.

5.3 Our suppliers and service providers are required to follow our data processing and security standards. The data we provide to them, including your personal data, is provided only in connection with the performance of their tasks. They are not authorized to use your personal data for purposes other than those set out in this policy.

Data transmission to payment service providers:

 

 

Data transfer to newsletter mailing companies:

We transfer your data to Mailchimp for the dispatch and user management of newsletters.

How Mailchimp protects and uses your data can be found here: Notes on the General Data Protection Regulation: https://eepurl.com/gv_uXD

 

 

6 Opt-in or opt-out with regard to direct marketing

6.1 We and selected third parties may use the information you give us on our Website and Apps for direct marketing purposes to send you updates, newsletters, event notifications or other communications that we think may interest you.

6.2 If required by law, your consent will be obtained before we send direct marketing material to you. In any case, we will give you the opportunity to opt-out on every communication sent.

6.3 You may opt-out of receiving direct marketing materials from us at any time by contacting us by email at the email address provided in Section 17 or by using the opt-out options provided in our email communications.

7 Analysis and display tools

7.1 To ensure that our online advertising is targeted to you and of interest to you, we analyze your behavior on our websites, partner websites and apps, and your interactions with us. For example, we track when you click on articles or our advertisements (which are on our websites or external websites), when you interact with us on social media (by mentioning us or our products), when you communicate with us directly (including through our chatbot tools used on social media), when you purchase products from us, when you attend our events, when you open and interact with our marketing communications, and where you come from when you visit us on our website or download our apps.

7.2 We use programs from third parties. For this purpose, we use cookies or similar technologies to collect data about your usage behavior and to provide you with interest-based advertisements.

7.3 We also use third-party tools, including Facebook Custom Audience and Google Customer Match, to serve ads to you on external platforms (including Facebook, YouTube and Google). These tools are provided by external providers, such as by and Google. They enable the matching of A2A Holding GmbH customers/visitors with Facebook or Google users* in order to provide tailored advertising. For this purpose, we share your data with the relevant providers (e.g. Facebook and Google) and use cookies or similar technologies on our website to analyze how effective our advertising presence is on other websites. For more information about Facebook's or Google's use of data, please see the following link: https://www.facebook.com/ads/about or https://suppor t.google.com/google-ads/answer/6379332?hl=en. You can opt out of receiving advertising through this tool via your Facebook or Google settings, or also by contacting us by email, as detailed in section 17 below.

8 Cookies and other technologies

8.1 We collect data automatically through the use of "cookies". Cookies may be set by us or by third parties. A cookie is a text file containing a small amount of data that a website can send to your browser and then store on your computer as an anonymous tag to identify your computer, but not you. Some of the pages on our site use cookies to provide you with better services when you return to the site. You can set your browser to notify you before you receive a cookie; this gives you the opportunity to decide whether to accept the cookie. You can also set your browser to disable cookies. If you do so, some services on our website may not function properly.

8.2 We also use web beacons, also commonly known as "one-pixel GIFs", "clear GIFs" or "tags". Web beacons are small graphic files that may be included on our website. Web beacons allow us to optimize our products and services and provide us and third-party partners with analytics data, such as how many visitors our website has. We may also use web beacons in our email correspondence to determine whether you open an email or take further action. We also work with other organizations to place our web beacons on their websites or in their advertisements. We do this so that we can compile statistics about how often clicking on an advertisement on an A2A Holding GmbH website or an advertising partner results in a purchase or other interaction on an advertising partner's website.

8.3 For our Apps, we collect data automatically through the use of device IDs ("IDs"). An ID is a specific sequence of numbers and letters ("string") that is associated with your device but does not identify you. The ID allows us, as well as third parties we select, to track your behavior when you use the App. Nearly every app uses ID technology. IDs serve several purposes; for example, they remember your preferences and generally provide a better user experience. IDs can tell us, for example, if you've used our app before or if you're doing so for the first time. They can also ensure that ads you see through the app are tailored to you and your interests. IDs are extremely useful for improving your user experience because of how they work.

8.4 More information about the specific cookies and web beacons used on this website is available in the Cookie Policy.

9 Links to other websites and social media

9.1 Links to other websites are provided for information purposes only. Other websites are beyond our control and are not covered by this policy. When you access other websites via the links provided, the operators of the respective websites may collect data about you, which the operators may then use in accordance with their respective privacy policies in a manner that may differ from our policy.

9.2 On some pages of our website, third-party content, applications or plug-ins may be provided that track and/or optimize your use of content, applications or plug-ins. For example, if you share an article using a social media share button (e.g., Facebook, Twitter, or Google Plus) on our website, this process is recorded by the social network that created the button. More information about social media plug-ins on our website can be found in our Cookie Policy.

10 Data retention

10.1 We will not keep your data longer than is necessary for our business purposes or due to legal or regulatory requirements.

10.2 We will retain your data for as long as you have an account with one of our brands and further if necessary to comply with our legal obligations, such as to retain the data for tax and accounting purposes. Your data will be retained in accordance with our internal data retention policies.

10.3 If you object to receiving direct marketing material from us or opt-out of receiving such material, we will remove your contact details and consent to marketing activities to ensure that you do not receive any future marketing communications from us. Personal data will not be deleted by us if it is required for investigation purposes or in the context of a legal dispute. In such a case, it will be stored until the matter is fully resolved.

10.4 In all cases, we will continue to protect your personal data in accordance with the provisions contained in this Policy. We will also routinely update our data to ensure that it is always up to date.

11 Your rights

11.1 Depending on applicable law, you may have the following rights with respect to your personal data in certain circumstances:

  • (a) Right to access your personal data. If you would like a copy of the personal data we hold about you, please contact us at the email address below. Before responding to your request, we may ask you to verify your identity and provide further details about your request. We will attempt to respond to your request within a reasonable time, and in any event within the time period required by law.
  • (b) Right to rectification, erasure or restriction of processing of your personal data. If you wish to rectify, erase or restrict the processing of your personal data, please contact us at the email address provided below. It is your responsibility to ensure that you provide truthful, accurate and complete information and to keep it up to date.
  • (c) Right of withdrawal. If you have given your consent to the processing of your data, you can revoke it at any time by contacting us via the e-mail address given in section 17 below.
  • (d) Right to data portability. You may ask us to assist you in transferring some of your data to other companies. In this regard, you have the right to request that we transfer your data to another company in an easily readable format. You may make your request by emailing us at the email address provided below.
  • (e) Right to object. You may object to the way we process your personal data or to direct marketing based on profiling, where there is legitimate interest in doing so, by submitting your request by e-mail to the e-mail address provided below.
  • (f) The right not to be subject to automated decision-making processes. (for more details, please refer to Section 17 below).
  • (g) Right to complain to a supervisory authority. You may contact your local supervisory authority if you have a complaint regarding the way we handle your personal data.

11.2 If you have set up a user account, you can use your user account to access and obtain a copy of the personal data we have about you, as well as make corrections or additions to inaccurate data or delete it. You can also close the user account at any time.

11.3 If you wish to exercise any of your rights set out above, please contact us at the email address set out in clause 17 below.

12 Profiling

12.1 We may use your information to try to learn more about you so that we can better predict, if necessary, what products and services you may be interested in.

12.2 On some of our e-commerce websites, we engage service providers who use automated decision-making processes to check your address and creditworthiness. This enables us to ensure that we use accurate address data and to assess the risk of non-payment for our products and services.

13 Data security

13.1 We use physical, technical and administrative measures to protect your personal data stored by us against unauthorized access, collection, use, disclosure, copying, modification or deletion. All data you provide to us is stored on secure servers.

13.2 If you have a password to access our Website or App, you are responsible for keeping the password secure and confidential.

14 Worldwide transmission

14.1 Due to the fact that the Internet provides a global environment, the collection and processing of personal data via the Internet necessarily involves the international transfer of data. While we usually store personal data that we collect about you through our website in your region (for example, in the European Economic Area in the case of visitors from Europe), your personal data may also be transferred to parties outside your region (where different data protection laws apply, e.g., in the U.S.), including to affiliates of A2A Holding GmbH.

14.2 If this occurs, we have implemented safeguards and data protection solutions to ensure that your data is adequately protected in third countries, e.g. by using standard contractual clauses or relying on the Privacy Shield where applicable. If you would like more information about this, please contact us via the email address provided in section 17.

15 Use of the website by minors

15.1 By using this website, you confirm that you are over 16 years old. If you are 16 years old or younger, you must first obtain the consent of your parents/guardians before you send us data via our website or apps. Without this consent, the provision of data is prohibited. If you still send us data, we will stop processing this data as soon as we become aware of it.

  1. Amendments to the Directive

16.1 This Policy was last updated on 09/25/2020. Each time this Policy is materially changed, a notice will be posted on our website for a period of 30 days. You agree to accept the respective changes by continuing to use our website or app.

17 Questions, concerns and complaints regarding the policy, contact details of the data protection officer

17.1 This website is maintained by A2A Holding GmbH. If you have any questions, concerns or complaints regarding the policy or our handling of your data, please send us an e-mail to datenschutz@armargentum.com.