Privacy Policy of A1 Digital Deutschland GmbH

We in A1 Digital Deutschland GmbH (hereinafter referred to as "A1 Digital" or "we") are committed to protection of your personal data. We handle your personal data confidentially and in accordance with applicable data protection laws. We have prepared this privacy statement in order to fulfil our information obligations in accordance with the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) and to explain you what personal data we process about you, to what extent, for what purpose and which data protection rights you are entitled to. Data protection regulations distinguish between the controller and the processor of personal data. A1 Digital may act as controller or processor of your data. We may be the controller of data that you provide to us by interacting with us or data that we collect to provide our services. Whenever we process personal data on your behalf, we will act as processor of data and the General Terms and Conditions of A1 Digital Deutschland GmbH for processing of personal data pursuant to Art. 28 GDPR (GTC DPA) shall apply, unless otherwise agreed.

Who is responsible for data processing?

Responsible for data processing is A1 Digital Deutschland GmbH, St.-Martin-Straße 59, D-81669 Munich. The A1 Digital Data Protection Officer can be reached by letter addressed to "DPO" at the above address, or by e-mail to datenschutz@a1.digital.

What data is processed?

We process personal data that you send us via our website, data that we receive or collect during our interaction with you and data that we need in order to enter into a contract with you and to provide our services.

To the categories of processed data belong in particular:

  • Your company data: Company name, company address (street, house number, postal code, city, country), VAT or commercial register number.
  • Your contact details and financial data: E-mail address, telephone number, fax number, bank details.
  • Marketing data (e.g. your preferences),
  • Customer inventory (e.g. SIM cards used; products and services from us that you use through a business relationship with Telekom Austria AG or its subsidiaries);
  • Documents (e.g. tender documents, offers, contracts, confidentiality declarations, self-assessments) with (any) contact details of the business partner's employees (e.g. name, e-mail address, function)
  • Other personal data that you or third parties make available to us with your consent or otherwise permissibly during the initiation of a contract or during the contractual relationship, such as: Personal master data, identifiers and roles (e.g. name, date of birth, gender, profession, position, identification data, authority to sign or represent);
  • Information about you that has been made public by you (e.g. LinkedIn Profile). This term does not include sensitive data under data protection law ("special categories of personal data" within the meaning of Art. 9 GDPR); this includes in particular racial or ethnic origin, political opinions, religious or ideological beliefs, trade union membership, genetic or health data.

 

When using our services the following data is processed:
  • Data that you store on our servers when using our services,
  • Usage data required for reliable provision of our services (automatically generated log or connection data, e.g. the IP address of the device with which you access a service, date and time of registration).

 

The following data is processed when you access our website:
  • Usage data, which are necessary for the functionality of the website and individualization of the viewed contents (automatically occurring log or connection data, e.g. the IP address of the device with which you access the website or a service, date and time, browser type, system configuration, the previously visited page, the file request of the client - file name and URL. For information about tools and cookies that we use for our website, please read „Cookies, Website Tools and Social Media Notice “.

 

On what legal basis and for what purposes are your data processed?

Your personal data will be processed with your consent or based on one of the other legal bases provided by GDPR.

Data processing within the scope of your consent (Art. 6 para. 1 (a), 7 GDPR)

When you give us your consent for processing of your personal data, it will be processed exclusively for the purposes and to the extent agreed in the declaration of consent.  We use your personal data to provide you with information about our services and products, or products and services of third parties and for communication with you. In doing so, we use the following communication channels, depending on the information you have provided us with: Phone, e-mail, SMS, post or social media.

Please note: You can also revoke any consent you have given us at any time with effect for the future. To do so, simply use this Website or our contact options (see "Who is responsible for data processing").  If you revoke such consent, this will have no effect on the fulfilment of our contractual obligations, but we will no longer use your data for the purposes indicated in the consent declaration.

Data processing for the fulfilment of contractual obligations (Art. 6 Para. 1 (b) GDPR)

We process company, contact, administrator and other contractual data for the provision, administration and invoicing of products and services purchased by you, the customer, from A1 Digital, as well as for the fulfilment of (pre-)contractual obligations with you, our supplier or business partner. More information on the processing of personal data for the fulfilment of contractual obligations can be found in our Terms and Conditions. We process your data to inform by telephone, post, SMS or E-mail (depending on the information you have provided us with) about changes or any important information concerning your contract, for example an adjustment of the monthly fee, changes in the scope of services or temporary restrictions of our services (e.g. due to maintenance work).

Data processing for the fulfilment of legal obligations (Art. 6 para. 1 (c) GDPR)

The processing of personal data may be necessary for the purpose of fulfilling various legal obligations (e.g. data relevant to tax and duty legislation). Please note that we may be obliged to provide courts and administrative authorities with information about your personal data processed by us if there is a legal basis for doing so. In such case, we will inform you immediately about the transfer, unless we are obliged to keep this information confidential by law or by order of a court or administrative authority. We reject requests for information without an appropriate legal basis.

Data processing for purpose of legitimate interests (Art. 6 para. 1 (f) GDPR)

Data processing may be carried beyond the actual fulfilment of the contract for purpose of our legitimate interests or legitimate interest of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data. A data processing for the protection of legitimate interests is carried out, for example:

  • for the protection of the company's assets as well as our employees and business partners or according to due diligence requirements based on the A1 Compliance Guidelines, such as:
    • Integrity checks of existing and potential contractual partners (checks against official sanctions lists and media sources)
    • Credit checks (checks on previous payment history and credit from credit agencies)
  • for the evaluation and selection of the provider in accordance with the vendor selection process (information related to tendering and bid solicitation phase, contract preparation or conclusion)

These checks do not lead to any automated decision making with regard to existing or potential contract and business relationship. However, if information is not compatible with our compliance guidelines or information is missing, we may refrain from concluding a contract with you or demand additional information. If you have any objections, simply use our contact options and indicate your concerns.

We also use automated data processing procedures to improve our services. Such procedures are referred to as "profiling" and include in particular processing:

  • to maintain an overview of your interest in our services, as well as to assign internal user categories to you, so that we can recommend products and services tailored to your interests
  • to improve and personalize your experience and display more relevant information or advertisements on our website or on third party sites
  • to identify and correct possible defects in our services and also to further improve our services
  • for fraud investigation and to detect abuse
  • to provide better products and services that are appropriate to user behavior and to improve contact with users

 

Who are the recipients of the personal data?

For the purpose of registration, activation of the products or services you have selected, we may need to transfer certain data, such as your company and contact details, to the respective licensor, supplier and partner of these products or services. In case of reselling of products and services, the service or license terms of the respective provider apply to the use of such third party services, and with regard to the processing of personal data, the relevant data protection terms of the respective provider apply.

We will not transfer your data to unauthorized third parties without your consent. However, we may be legally obliged to transfer your data to courts, public prosecutors, police or other authorities. If you do not comply with your contractual obligations, we may commission a debt collection agency. In this case, you will be notified in advance so that you can take any action.

In order to provide service support to the products or services you have selected, we may transfer your personal data to Telekom Austria AG and its subsidiaries. We may also engage third parties to perform certain tasks on our behalf, such as IT and cloud services, invoice printing, administration and troubleshooting tools, logistics, sales, etc. Even if we engage such processors, we remain responsible for the protection of your data. For this reason, all processors are of course contractually obliged to keep your data confidential and to comply with data protection regulations. We only use processors outside the European Union if the European Commission has issued an adequacy finding for such third country or if we have agreed appropriate guarantees or binding internal data protection rules with the processor.

Security of processing

We have implemented effective technical and organisational measures to protect your data, and our employees are also trained on how to safely handle personal data.

How long is personal data stored?

We generally delete your personal data after termination of the contractual relationship, but at the latest after all legal obligations to retain data have expired. A longer storage period exists if this data is still needed to charge or collect fees, to process complaints or to fulfil other legal obligations. In addition, access to the above-mentioned data is restricted.

Your usage data, insofar as this is not required for the purpose of charging fees, will be deleted in accordance with legal requirements, after legal obligations to retain data have expired.

It is also possible that instead of deleting the data, it may be made anonymous. In this case, any personal reference will be irretrievably removed, meaning that the obligations to erasure of data under data protection law will no longer apply.

What rights do you have?

You can exercise the following rights with regard to the processing of your data:

  • Right to information in accordance with Art. 15 GDPR - You can demand confirmation from us as to whether and to what extent we are processing your data. We will however not disclose details of our company and business secrets within the scope of our duty to provide information. In order to protect your data, it may be necessary to carry out an identity check, upon any request for information.
  • Right to rectification in accordance with Art. 16 GDPR - If we process your personal data that is incomplete or incorrect, you can request us to rectify or complete it at any time.
  • Right to erasure of data in accordance with Art. 17 GDPR - You can demand that we erase your personal data if we process them unlawfully or if the processing interferes disproportionately with your legitimate interests. Please note that there may be reasons that prevent immediate deletion, e.g. in case of legal obligations with respect to data retention.
  • Right to restriction of processing in accordance with Art. 18 GDPR - You can demand that we restrict the processing of your data if:
    • you dispute the accuracy of the data, for a period of time which enables us to verify the accuracy of the data.
    • the processing of the data is unlawful, but you refuse to delete it and instead demand a restriction on the use of the data,
    • we no longer need the data for the intended purpose, but you still need the data to assert or defend legal claims or
    • you have lodged an objection to the processing of the data.
  • Right to data portability in accordance with Art. 20 GDPR - You can demand that we provide you with the data you have entrusted us with for safekeeping in a structured, common and machine-readable format, provided that:
    • we process this data on the basis of a revocable consent granted by you or for the fulfilment of a contract between us, and
    • this processing is carried out by means of automated procedures.
  • Right to object under Art. 21 GDPR - You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out on the basis of Art. 6 paragraph 1 (e) GDPR (data processing in the public interest) and Art. 6 paragraph 1 letter (f) GDPR (processing for purpose of the legitimate interests). If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

The rights to information and data erasure are subject to the restrictions of §§ 34 and 35 BDSG. If you wish to exercise any of the rights mentioned above, please use our contact details. We may need to request additional information to confirm your identity and protect your rights and your privacy, e.g. a copy of a valid ID with your signature.

If you think that the processing of your personal data violates any applicable legal requirements, you have the right to complain to a competent data protection supervisory authority (Art. 77 GDPR). We kindly ask you to contact us before, so that we can clarify any questions or concern you may have.

Update

This privacy policy is applicable from 08/2020 and any future changes to our privacy policy will be posted on this website. We therefore recommend you review it regularly for new features or changes.

Cookies, Website Tools and Social Media Notice

Cookies are used on our website. Cookies are text files that the browser stores on the user's device when a website is accessed. We use cookies to adapt our offers to your needs, to make it easier for you to use our services, and to analyse the way our services operate and how they are used. If you do not wish data to be stored in cookies, you can delete or deactivate cookies that are already on your computer at any time. You can make settings in your browser to control the use of cookies. However, blocking certain types of cookies may result in a compromised experience with the website and services we provide. You can revoke your voluntarily given consent to cookies at any time without any reason. If you wish to manage or change your cookie settings, simply use our

Necessary Cookies

These cookies are necessary for the functioning of the website and cannot be deactivated in your systems. In general, these cookies are only set in response to actions you take in response to a service request, such as setting your privacy preferences, logging in, or filling out forms. You can set your browser to block these cookies or to notify you about these cookies. However, some areas of the website may not function properly.

Performance Cookies

These cookies enable us to count visits and traffic sources so that we can measure and improve the performance of our website. They help us answer questions about which pages are most popular, which are least used and how visitors move around the site. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we cannot know when you visited our website.

Functional cookies

With these cookies, our website is able to provide extended functionality and personalization. They may be set by us or by third parties whose services we use on our pages. If you do not allow these cookies, some or all of these services may not function properly.

Marketing cookies

These cookies can be set via our website by our advertising partners. They may be used by these companies to profile your interests and show you relevant ads on other websites. They do not store personal information directly, but are based on a unique identification of your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social-Media-Cookies

These cookies are set by a number of social media services that we use on the Site to enable you to share our content with your friends and networks. These cookies are able to track your browser across other websites and create a profile of your interests. This may affect content and messages you see on other websites. If you do not allow these cookies, you may not be able to use or view these sharing tools.

Google Analytics

On our websites we use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by cookies about your use of this website is usually transferred to a Google server in the USA and stored there. However, by activating IP anonymisation, your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before.

On our behalf, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide us with further services related to the use of the website and the Internet. The IP address transmitted by your browser within the scope of Google Analytics is not combined with other data from Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout.

This website uses the analytics features for remarketing, Google Signals, reports on impressions on the Google Display Network, DoubleClick Campaign Manager integration and Google Analytics reports on performance by demographic characteristics and interests.

To enable us to obtain information about the use of this website on various devices, we use cookie technology to set up a pseudonymised user ID that does not contain any personal data and does not transmit such data to Google. The collection and storage of data can be revoked at any time with effect for the future by a browser plug-in from Google (tools.google.com/dlpage/gaoptout). You must perform this opt-out on all systems that you use, for example in another browser or on your mobile device. Further information about Universal Analytics can be found here: support.google.com/analytics/answer/2838718

We also use Google Analytics to evaluate data from double-click cookies and also AdWords for statistical purposes. If you do not want this, you can deactivate this via the Ads Preferences Manager: adssettings.google.com.

DoubleClick by Google

This website uses Doubleclick by Google. This is a service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Doubleclick by Google uses cookies to present you with advertisements relevant to you. This involves associating a pseudonymous identification number (ID) with your browser in order to verify which ads were shown in your browser and which ads were viewed. The cookies do not contain any personal information. DoubleClick's use of the DoubleClick cookie only enables Google and its partner websites to serve ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transferred by Google to a server in the USA for evaluation and stored there. A transfer of the data by Google to third parties only takes place due to legal regulations or within the scope of order data processing. Under no circumstances will Google combine your data with other data collected by Google. By using our website, you agree to the processing of the data collected about you by Google and to the aforementioned manner of data processing and the stated purpose. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website. You can also prevent the collection of data generated by the cookies and related to your use of the websites to Google and the processing of this data by Google by downloading and installing the browser plugin available at www.google.com/settings/u/0/ads/anonymousunder the item DoubleClick deactivation extension. Alternatively, you can deactivate the Doubleclick cookies on the Digital Advertising Alliance website at aboutads.info/choices.

Mouseflow

This website uses Mouseflow, a web analysis tool from Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark, to record randomly selected individual visits. This results in a protocol of mouse movements, mouse clicks and keyboard interaction, with the intention of randomly reproducing individual visits to this website as so-called session replays, as well as evaluating them in the form of so-called heat maps and deriving potential improvements for this website. The data collected by mouseflow is not personal and will not be passed on to third parties. The storage and processing of the collected data takes place within the EU. If you do not want Mouseflow to collect your data, you can object to it on all websites that use Mouseflow by clicking on the following link: https://mouseflow.de/opt-out/.

Marketo

The website uses Marketo, a web analytics and marketing service provided by Marketo EMEA Ltd. in Dublin, Ireland ("Marketo"). The information generated by the cookie about your use of this website is generally stored on a Marketo server in Ireland and processed there. On our behalf Marketo uses this information to evaluate the use of its websites and online services, to generate reports on website activity and to provide other services related to website and internet usage. The Marketo cookies are also used to tailor the content of the websites to your interests and to store the data you have entered in forms on this website in the cookie to make it easier for you to fill in forms in the future. For more information about Marketo's privacy policy, please visit https://documents.marketo.com/legal/privacy/.

You can prevent the functionality and advertising cookies from being saved by adjusting your browser software settings accordingly; in this case you may not be able to use all the functions of the website to their full extent. You may also object to the collection of data generated by the cookie and relating to your use of the websites by Marketo and to the processing of this data by Marketo via the following link: https://docs.marketo.com/display/public/DOCS/Understanding+Privacy+Settings

Drift

To provide you with a good personal service, we use the live chat software of the company Drift, Inc., 222 Berkeley Street, Boston, MA 02116, USA. Drift uses, among other things, "cookies" that enable a personal conversation in the form of a real-time chat on the website with you. Your data transmitted in the live chat is stored on servers of Drift, Inc. in the USA. By using the live chat, you consent to this transmission. The Drift, Inc. privacy policy can be found under https://www.drift.com/privacy-policy/.

Social Media

This website may host various social media applications or services that allow you to share content with other users ("Social Media"). Any personal information or other information you contribute to social media applications may be read, collected and used by other users of that social media application over which we have little or no control.

Facebook

The collection and processing of personal data on Facebook Fanpages is carried out by Facebook. You can find more detailed information about which data Facebook collects and processes in this process in Facebook's data protection information (https://www.facebook.com/privacy/explanation).

If you become a fan of our fan page or click on "Like", you will be added to the list of our fans provided by Facebook. We have access to the public information of our fans' profiles. You can control the amount of publicly viewable information on your profile in your Facebook settings. If you no longer want to appear as a fan of our fan page, you can also change this in your Facebook settings at any time. In this case your profile will no longer appear in the list of fans on our fan page. If you are not registered with Facebook or if you simply visit our fan page without becoming a fan, then we do not receive any information from Facebook about your visit to our fan page.

Facebook compiles statistics about the fans on a fan page and makes them available to the users of a fan page. This is anonymous demographic information about our fans, such as age, gender, or residence. A conclusion on individual profiles of our fans is not possible. We use the data provided by Facebook to select the information that is particularly relevant to our fan groups for our posts or to commission targeted advertising on Facebook. If you do not wish to receive targeted advertising from Facebook, you can control this at any time via your Facebook settings.

Facebook Remarketing

On this website remarketing tags of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA are integrated. When you visit this site, the remarketing tags establish a direct connection between your browser and the Facebook server. Facebook thereby receives the information that you have visited our site with your IP address. This enables Facebook to assign your visit to our pages to your user account. We can use the information thus obtained to display Facebook Ads. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Facebook. You can find more information on this in the Facebook privacy policy. If you do not wish to collect data via Custom Audience, you can deactivate Custom Audiences at www.facebook.com/ads/website_custom_audiences.

LinkedIn

Our website uses features of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of our pages that contains LinkedIn features, a connection to LinkedIn servers is established. LinkedIn will be notified that you have visited our sites using your IP address. If you click on LinkedIn's "Recommend Button" and are logged into your LinkedIn account, LinkedIn is able to track your visit to our site to you and your account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. For further information, please refer to the LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy.

XING

When you visit our XING site, XING records your IP address and other information that is stored on your PC in the form of cookies. This information is used to provide us, as the operator of the XING pages, with statistical information on the usage of the XING page. XING provides more detailed information on this at the following link: https://www.xing.com/terms.  We expressly point out that XING stores the data of its users (e.g. personal information, IP address, etc.) and may also use this data for business purposes. More detailed information on XING's data processing can be found in the XING Privacy Policy at https://privacy.xing.com/en/privacy-policy.

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Privacy Statement A1 Digital Deutschland GmbH

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Privacy Statement A1 Digital International GmbH

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