Privacy Policy of A1 Digital Deutschland GmbH

In this privacy policy, A1 Digital Deutschland GmbH (hereinafter referred to as "A1 Digital" or "we") explains which personal data we collect and process through interactions with you or through your use of our services. Furthermore, we describe the purposes of processing for which A1 Digital is the data controller.

Collection of your data

We collect the following data:

General Data

If you conclude a contract with us, we process the following data:

  • Your company data: Company name, company address (street, house number, post code, city, country), VAT or commercial register number.

  • Your contact data: Email address, telephone number, fax number, job title.

  • Administrator data: First name, last name, gender, username, password, email address, telephone number, fax number.

  • Other contractual data: about products and services related to A1 Digital

 

Usage Data

When using our services, the following data is processed:

  • We process and store the data that you store yourself on our servers when using our services.
  • When using our services, we automatically store any log or connection data, e.g. the IP address of the device that you use to access a service, as well as the date and time of login. The processing of this data is required for the reliable provision of our services.

 

When accessing our websites, the following data is processed:

  • When visiting our webpages, we automatically store any log or connection data, e.g. the IP address of the device that you use to access the website or service, date and time, browser type, system configuration, referrer URL (the previously visited page), and the client's file request (filename and URL), as far as this is required for the functionality of the website and individualisation of the content displayed.
  • In order to enable recognition of your browser, small text files are used, which are stored in the cache of your internet browser ("cookies"). Without your explicit consent, this information will not be used to identify you as a visitor to the site nor will this anonymised data be merged with your personal information.
  • We use different tools for our websites, which are described in the section "Website Tools". We use these tools to show you the information that is relevant for you.

 

Processing your data

  • We process your company, contact, administrative, and other contractual data for the purpose of providing, servicing, administering, and charging our products and services that you purchase through A1 Digital.

  • For the purpose of registering and enabling the products or services you choose, we may need to provide certain information, such as your company and contact information, to the applicable licensor, supplier and partner of those products or services.
    In the case of brokering products and services, the service and licensing terms of the respective provider apply for the use of such third-party services, and the processing of personal data is subject to the relevant data protection conditions of the respective provider.

 

The above-mentioned processing of your data - insofar as this concerns personal data - is necessary for the conclusion or for the fulfilment of the contract you entered into with us. The legal basis for these data processing procedures for contract initiation and performance is article 6 para. 1 b) GDPR: If you do not provide us with this information, or you do not fully provide it, we may be unable to fully perform our contractual obligations or we may be unable to enter into a contract with you.

Profiling

We use automated data processing techniques to improve our services, improve contact, and analyse user behaviour. Such methods are referred to as profiling. Details on the processing can be found in the following processing steps.

  • We also process your master data and other personal data internally to detect and rectify disruptions in our services, to detect fraud, to detect misuse and also to further optimise our services. If you order from us as an individual merchant/sole proprietorship, we collect personal data on previous payment history and credit information on the basis of mathematical-statistical procedures at credit agencies. Credit agencies store personal data for providing of information.

  • The above-mentioned processing of your data is necessary for the conclusion or for the fulfilment of the contract you entered into with us or for the preservation of our legitimate economic interests. As far as the legal basis for these data processing procedures is not contract initiation and execution in accordance with Article 6 para. 1 b) GDPR, the basis is the preservation of the legitimate interests of the controller in accordance with article 6 para. 1 f) GDPR.

  • We process the billing information and other personal information for a purpose consistent with the original processing, that being to create an overview of your interest in our services and to assign you internal user categories. Building on this, we recommend suitable services tailored to your user behaviour with additional benefits. The legal basis for these data processing procedures for contract initiation and performance is article 6 para. 1 b) GDPR.

  • We use your usage data to improve and personalize your experience. In addition, we use the data to display even more appropriate information or advertising on our website or on the pages of third parties. The legal basis for these data processing procedures is the preservation of the legitimate interests of the controller in accordance with article 6 para. 1 f) GDPR, in this case, the provision of improved products and products more suited to user behaviour, as well as their advertisement online.

Data processing on behalf

Even if we commission a processor, we remain responsible for protecting your data. We only use processors outside the European Union, if there is an adequacy decision of the European Commission for the third country concerned or if we have agreed appropriate guarantees or binding internal data protection rules with the respective processor.

Erasure

Your master data and other personal data is erased in principle after termination of the contractual relationship, but at the latest after expiry of all legal storage requirements. A longer storage period is required if this data is still needed to charge or collect fees, to process complaints or to fulfil other legal obligations, in particular those arising from tax and commercial law. In addition, access to the mentioned data is restricted. Your usage data, unless required for purposes of charging fees, is erased in accordance with statutory provisions, at the latest with the end of statutory retention requirements.

There is also the possibility that the data is anonymised instead of erased. In this case, any personal reference is irretrievably removed, meaning that data protection erasure obligations no longer apply.

Consent

If you have given us the corresponding consent, we will also process your data for:

  • Product information & offers: A1 Digital sends you its newsletter by email, which informs you about offers, as well as products and services of third parties.

  • Data transfer within Telekom Austria AG: Your data may also be used for the respective purposes of Telekom Austria AG, i.e. Telekom Austria AG and its subsidiaries.

Please note: You can also revoke your consent at any time with effect for the future. Simply use this website or one of our contact options (see the chapter “Data Controller”). If you revoke such consent, this will not affect the fulfilment of our contractual obligations. If you revoke your consent, we will no longer use your data for the purposes mentioned.

Disclosure and further rights

You may assert the following rights with regard to the processing of your data:

As the data subject, you have the right to access your stored data in accordance with article 15 GDPR, the right to rectification in accordance with article 16 GDPR, the right to data erasure in accordance with article 17 GDPR, a right to restriction of processing in accordance with article 18 GDPR, as well as a right to data portability in accordance with article 20 GDPR. For the rights to information and data erasure, the restrictions according to sections 34 and 35 of German BDSG.

You have the right to object, at any time and for reasons of your own particular situation, to processing of your personal data based on article 6 para.1 (e) of the GDPR (data processing in the public interest) and article 6 para. 1 (f) GDPR (data processing on the basis of a balance of interests). If you object, we will no longer process your personal information, unless we can establish compelling legitimate grounds for processing which outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, pursuing or defending legal claims.

If you believe that the processing of your personal data violates legal requirements, you have the right to lodge a complaint with a responsible data protection supervisory authority (Article 77 GDPR in connection with section 19 of German BDSG). We kindly ask you to contact us in order to clarify any questions.

Assertion of the rights

If you want to assert one of the aforementioned rights to us, simply use the respective contact options. If in doubt, we may need to request additional information to confirm your identity, e.g. a legible copy of a valid photo ID with signature. This is to protect your rights and privacy..

Data controller, Contact and Data Protection Officer

The responsible body for the processing of your personal data described here is A1 Digital Deutschland GmbH, Data Privacy, St. Martin-Strasse 59. 81669 Munich. A1 Digital’s data protection officer can be reached by post by sending a letter "FAO Data Protection Officer" to the above address, or by email to privacy@a1.digital.

Information provided to Authorities

Please note that we are obliged to provide courts and administrative authorities with information about your personal data processed by us, as far as there is a corresponding legal basis for doing so. In such a case, we will inform you immediately about the transfer, except where we are obliged to secrecy by law or by order of a court or an administrative authority. We reject any request for information without legal basis. The legal basis for data processing to fulfil legal obligations is article 6 para. 1 c) GDPR.

Website Tools

Google Analytics

We use Google Analytics, a web analysis service of Google Inc. ("Google"), on our websites. Google Analytics uses "cookies", text files that are stored on your device and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, by activating IP anonymisation, your IP address will be shortened by Google beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. Google will use this information on our behalf to evaluate your use of the websites, to compile reports on website activity, and to provide us with other services related to website activity and internet usage. The IP address collected by your browser as part of Google Analytics will not be merged with other Google data.

You can prevent the storage of cookies by setting your browser software accordingly; however, we point out that in this case you may not be able to fully use all the functions on our website. Furthermore, you can prevent Google’s collection of data generated by the cookie and related to your use of the website (including your IP address), as well as Google’s processing of this data, using the browser plug-in available to download and install under the following link:
http://tools.google.com/dlpage/gaoptout?hl=en

This website uses Analytics functions for remarketing, Google Display Network impressions reports, DoubleClick Campaign Manager Integration, Google Analytics reports on demographic characteristics and interests.

We use Google Analytics to analyse data from Double-Click-Cookie and also AdWords for statistical purposes. If you do not want this, you can prevent this through the Ads Preferences Manager:
https://adssettings.google.com/

DoubleClick by Google

„DoubleClick“ is a service provided by Google.

Cookies are used by DoubleClick to present advertisements relevant to you. Your browser will be assigned a pseudonymous identification number (ID) to check which ads have appeared in your browser and which ads have been viewed. The cookies do not contain any personal information. Using the "DoubleClick" cookies allows Google and its affiliate websites to place ads based on previous visits to our own or other websites on the internet. Google transmits the information generated by the cookies to a server in the USA for evaluation and stores it there. Google only transfers the data to third parties due to legal regulations or in the context of contracted data processing. In any case Google will never merge your data with other data collected by Google.

The legal basis for this is our legitimate interest. In the context of the required balance of interests, we have weighed your interest in the confidentiality of your personal information against our interest in providing this website. In this case, your interest in confidentially is outweighed.

You can also disable DoubleClick through the following options:
https://support.google.com/ads/answer/2662922?hl=en

Further information on DoubleClick: https://policies.google.com/technologies/ads?hl=en

Facebook Remarketing / Retargeting

Our website integrates remarketing tags from the social network Facebook, 1601 South California Ave., Palo Alto, CA 94304, USA. When visiting our site, the remarketing tags enable a direct connection between your browser and the Facebook server. Facebook then receives the information that you have visited our site with your IP address. As a result, Facebook can assign your visit on our pages to your user account. We can use the information obtained in this way for the display of Facebook ads. We point out that we as the provider of the webpages are not aware of the content of the data transmitted and its use by Facebook.

For more information, see Facebook’s Privacy Policy. If you do not want your data collected via Custom Audience, you can disable Custom Audiences here: https://www.facebook.com/privacy/explanation

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 visit one of our pages that contains LinkedIn features, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our webpages with your IP address. If you click LinkedIn's "Recommend Button" and are logged in to your LinkedIn account, LinkedIn will be able to associate your visit to our webpages with you and your user account. We point out that we as the provider of the webpages are not aware of the content of the data transmitted and its use by LinkedIn. For more information, see LinkedIn’s Privacy Policy:
https://www.linkedin.com/legal/privacy-policy

Mouseflow

Our website uses Mouseflow, a web analytics tool of Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark, to collect randomly selected individual visits (using only anonymous IP addresses). The result is a log of mouse movements, mouse clicks and keyboard interaction, and the intention is to reproduce individual visits to this site at random as so-called session replays and to evaluate them in the form of so-called heat maps in order to derive potential improvements for this website. The data collected by Mouseflow is not personal and will not be disclosed to third parties. The storage and processing of the collected data takes place within the EU. If you do not want your data collected by Mouseflow, you may object to this on all websites that use Mouseflow via the following link: https://mouseflow.de/opt-out/

Marketo

Our website uses Marketo, a web analytics and marketing service of Marketo EMEA Ltd. in Dublin, Ireland ("Marketo"). The information generated by the cookie about your use of this website is usually transmitted to 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 compile reports on website activity and provide other services related to website and internet usage. Marketo cookies are also used to adapt the content of the websites to your interests and to store the data you have entered in forms on this website in the cookie in order to facilitate the completion of forms in the future. For more information about data privacy at Marketo, visit: https://documents.marketo.com/legal/privacy/

Opt-out:
You can prevent the storage of cookies by setting your browser software accordingly; however, in this case you may not be able to use all the functions on our website to the fullest extent. You may also object to Marketo’s collection of the data generated by the cookie and related to your use of the website and Marketo’s processing of this data via the following link:
https://docs.marketo.com/display/public/DOCS/Understanding+Privacy+Settings

Oracle BlueKai

Our website also uses BlueKai a service from Oracle. By using this website, users agree to the processing of the data collected about them by Oracle. Oracle's privacy policy can be viewed at: 
https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html#12.
Via the following links you can deactivate the tracking under BlueKai: https://datacloudoptout.oracle.com/#optout or http://www.youronlinechoices.eu/

Updating

This Privacy Policy applies from 06/2018. Any future changes to our Privacy Policy will be posted on this website. You should therefore check the website regularly for new features or changes.


[i] Telekom Austria AG owns the following companies: A1 Telekom Austria AG, A1 Digital International GmbH, A1 Digital Deutschland GmbH, Telekom Lichtenstein AG, VIPnet d.o.o. (Croatia), Si.mobil d.d. (Slovenia), Mobiltel EAD (Bulgaria), one.Vip DOO Skopje (Macedonia) and Vip mobil d.o.o. (Serbia), Akenes SA

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A1D DE Data Privacy Policy

  • 28.06.2018
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