1.1. OBJECTIVE AND RESPONSIBILITY
- This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as “online service” or “website”). Details on these processing activities can be found in section 2.
- Details on data processing for the purpose of carrying out our business processes are described in section 3.
- The online service is provided by Brisen Group Holding Ltd (140, Archiepiskopou Makariou III Office 101B 3021, Limassol, Cyprus) – hereinafter referred to as “BDG”, “we” or “us” – who is also legally responsible under the data protection law.
- Please contact us if you have any questions or require additional information: Office.vienna@brisengroup.com
- Our online service is hosted by Infomaniak Network AG (Rue Eugène Marziano 25, 1227 Les Acacias (GE), Switzerland). The server location is Switzerland.
- The term “user” encompasses all customers, interested people, employees and visitors of our online service.
1.2. LEGAL BASES
In principle, we collect and process personal data based on the following legal grounds:
- Consent in accordance with article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
- Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to article 6 paragraph 1 lit. b GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
- Processing to fulfil a legal obligation in accordance with article 6 paragraph 1 lit. c GDPR, meaning that e.g. the processing of data is required by law or other provisions.
- Processing in order to protect legitimate interests in accordance with article 6 paragraph 1 lit. f GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.
The specific legal bases for the individual processing operations are specified in the following sections.
1.3. DATA SUBJECT RIGHTS
- You have the following rights with regards to the processing of your data through us:
- The right to lodge a complaint with a supervisory authority in accordance with article 13 paragraph 2 lit. d GDPR and article 14 paragraph 2 lit. e GDPR.
- Right of access in accordance with article 15 GDPR
- Right to rectification in accordance with article 16 GDPR
- Right to erasure (‘right to be forgotten’) in accordance with article 17 GDPR
- Right to restriction of processing in accordance with article 18 GDPR
- Right to data portability in accordance with article 20 GDPR
- Right to objection in accordance with article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
2.Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.
The data protection supervisory authority responsible for Brisen Group Holding Ltd is: Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, CY.
1.4. DATA ERASURE AND DURATION OF STORAGE
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.
1.5. SECURITY OF PROCESSING
- We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
- These security measures include in particular the encrypted transfer of data between your browser and our server.
1.6. TRANSFER OF DATA TO THIRD PARTIES, SUBCONTRACTORS AND THIRD PARTY PROVIDERS
- A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
- If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
- If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.
2. PROCESSING ACTIVITIES WITHIN THE SCOPE OF OUR ONLINE SERVICE
2.1. COLLECTION OF INFORMATION ON THE USE OF THE ONLINE SERVICE
- When using our online-service, information may be transferred automatically from the browser of the user to us; this information includes the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
- The processing of this information is based on legitimate interests in accordance with Article 6 paragraph (1) lit. f GDPR (e.g. optimisation of the online service) as well as to ensure the security of the processing in accordance with Article 5 paragraph (1) lit. f GDPR (e.g. for the defence and clarification of cyberattacks).
- This information will be automatically deleted latest 30 days after the termination of the connection, unless any other retention periods require otherwise.
- The collection of the data and the storage of the data in log files is essential for the provision of the online service. Therefore users are not entitled to the options of erasure, objection or correction.
2.2. ADOBE FONTS
- We integrate the fonts (“Typekit fonts”) of the provider Adobe, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser.
- The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration
- Service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland
- Legal basis: Legitimate interests (Art. 6 para. 1 lit. f GDPR)
- Privacy policy: https://www.adobe.com/de/privacy.html
- Data Privacy Framework (DPF): https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000TNo9AAG&status=Active.tbd
2.3. BING ADS
- This website uses tracking technologies of the Bing Ads service, which is provided and operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). Microsoft places a cookie on your device if you have reached our website via a Microsoft Bing ad. In this way, Microsoft Bing and we can recognize that someone has clicked on an ad, has been redirected to our website and has reached a previously determined target website (conversion website). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion website. Microsoft collects and processes information via the cookie, from which pseudonymous user profiles are created. These user profiles are used to analyze visitor behavior on our website and are used to display advertisements. No personal information about the identity of the user is processed. If you do not want Microsoft to collect and process this information, you can prevent the setting of cookies in your browser settings. You can also disable targeted and interest-based advertising from Microsoft (http://choice.microsoft.com/de-DE/opt-out).
- For more information about Bing Ads and Microsoft’s use of personal data for advertising purposes, see https://secure.bingads.microsoft.com/ und https://privacy.microsoft.com/en-US/privacystatement.
2.4. INFORMATION ABOUT GOOGLE SERVICES
- We use various services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland on our website.
For more information on the individual concrete services of Google that we use on this website, please refer to the further privacy policy.
- Through the integration of Google services, Google may collect information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.
The transmission to the USA depends on the function in which personal data is transmitted. As the responsible party, we ourselves may transfer data to Google in the USA for further use.
Google has committed to comply with the standard contractual clauses for the transfer of personal data to third countries (Standard Contractual Clauses – SCC).
More information about the Standard Contractual Clauses is available at
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractuals-clauses-scc_de
and at
https://policies.google.com/privacy/frameworks?hl=de
- We ourselves cannot influence which data Google actually collects and processes. However, Google states that, in principle, the following information (including personal data) may be processed, among others:
- Log data (in particular the IP address)
- Location-related information
- Unique application numbers
- Cookies and similar technologies
Information on the types of cookies used by Google can be found at https://policies.google.com/technologies/types.
- If you are logged into your Google account, Google may add the processed information to your account depending on your account settings and treat it as personal data.
- Google states the following about this, among other things:
“If you are not signed into a Google Account, we store the data we collect with unique identifiers associated with the browser, app, or device you are using. This allows us to ensure, for example, that your language settings are maintained across all browser sessions.
If you are logged into a Google account, we also collect data that we store in your Google account and consider to be personal data.” (https://privacy.google.com/take-control.html)
- You can prevent this data from being added directly by logging out of your Google account or also by making the appropriate account settings in your Google account. Furthermore, you can change your cookie settings (e.g. delete cookies, block cookies, etc.).
- You can find more detailed information in the privacy notices of Google, which you can access here: https://www.google.com/policies/privacy/
- You can find notes on Google’s privacy settings at https://privacy.google.com/take-control.html.
2.5. GOOGLE ADSERVICES
- This website uses the remarketing or “similar target group” function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
- You can be targeted with advertising by placing personalised and interest-based ads when you visit other websites in the so-called “Google Display Network”. “Google Remarketing” or the function “Similar target groups” uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website. These text files are used to record your visits and anonymous data about the use of the website. Personal data will not be stored. If you visit another website in the so-called “Google Display Network”, you may see advertisements that most likely take into account product and information areas previously accessed on our website.
Google’s privacy policy for remarketing with further information can be found here: http://www.google.com/privacy/ads/
The legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.
2.6. GOOGLE ADS CONVERSION-TRACKING
- We use “Google Ads” (formerly Google AdWords) on our website, a service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as “Google”). Google Ads enables us to draw attention to our attractive offers with the help of advertising media on external websites. This enables us to determine how successful individual advertising measures are. These advertisements are delivered by Google via so-called “AdServers”. We use so-called AdServer cookies for this purpose, through which certain parameters for measuring success, such as display of the ads or clicks by the users, can be measured. If you access our website via a Google ad, Google Ads will store a cookie on your PC. These cookies usually lose their validity after 30 days. They are not intended to identify you personally. The following information is usually stored as analysis values for this cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies enable Google to recognise your web browser. If a user visits certain pages of an Ads customer’s website and the cookie stored on their computer has not yet expired, Google and the customer will be able to recognise that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked via the websites of Ads customers. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. These evaluations enable us to recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising tools; in particular, we cannot identify users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. To the best of our knowledge, Google receives the information that you have called up the relevant part of our website or clicked on one of our ads. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, it is possible that Google will obtain and store your IP address.
- We use Google Ads for marketing and optimisation purposes, in particular to serve relevant and interesting ads to you, to improve campaign performance reports and to achieve a fair calculation of advertising costs. This is also our legitimate interest in the processing of the above data by the third-party provider. The legal basis is Art. 6 para. 1 p. 1 lit. f) GDPR.
- You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in the settings of your web browser. We would like to point out that in this case you may not be able to use all the functions of our website to their full extent. It is also possible to prevent the storage of cookies by setting your web browser to block cookies from the domain “www.googleadservices.com” (https://www.google.de/settings/ads). We would like to point out that this setting will be deleted when you delete your cookies. In addition, you can deactivate interest-based ads via the link http://optout.aboutads.info. Please note that this setting will also be deleted when you delete your cookies.
- Information of the third party provider: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.
- Further information on data use by Google, on setting and objection options and on data protection can be found on the following Google web pages:
Privacy policy: https://policies.google.com/privacy?hl=de&gl=en
Google website statistics: https://services.google.com/sitestats/en.html
2.7. GOOGLE ADS REMARKETING (SIMILAR AUDIENCES)
- This website uses the remarketing or “similar audience” function of Google Ads, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
- This function allows us to display interest-based and personalised advertisements to users when they visit other websites within the so-called “Google Display Network”. Google Remarketing uses cookies and similar technologies that are stored on your end device and enable an analysis of your use of the website. These technologies are used to record visits to this website and pseudonymous information about website usage.
- Based on this information, advertisements may be displayed that are likely to reflect product or information areas previously accessed on our website.
- The processing takes place only with your consent pursuant to Art. 6 para. 1 lit. a GDPR.
- Further information on Google Remarketing and data protection can be found at:
https://policies.google.com/privacy
https://policies.google.com/technologies/ads
2.8. GOOGLE ANALYTICS
- We use Google Analytics, a web analytics service of Google Ireland Limited (Gordon House Barclays Dublin Ireland – hereinafter “Google”), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Art. 6 para. 1 lit. a. GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by the users is transmitted to a Google server in the USA and processed there.
- Google acts on our behalf within the framework of order processing in accordance with Article 28 GDPR. We have concluded a data protection agreement with Google that contains the EU standard data protection clauses.
- In addition, we have concluded a shared responsibility agreement pursuant to Article 26 GDPR with Google for the use of Google’s measurement services (see https://support.google.com/analytics/answer/9012600). Within this framework, we have agreed with Google to be responsible for the fulfillment of information obligations and for ensuring data subject rights in accordance with Chapter 3 of the GDPR, as well as for the security of processing and reporting/notification obligations. (Articles 32 to 34 of the GDPR). Google will use the information to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and internet use. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
- We use Google Analytics to display the ads placed within advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “remarketing audiences”, or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users and do not have a harassing effect.
- We use Google Analytics with IP anonymization enabled.
- Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you during future website visits. Users can prevent the storage of cookies by setting their browser software accordingly.
- The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.
- For more information on data usage by Google, settings and revocation options, please visit Google’s websites:
https://policies.google.com/technologies/partner-sites?hl=en (“HOW GOOGLE USES INFORMATION FROM SITES OR APPS THAT USE OUR SERVICES “).
https://policies.google.com/technologies/ads?hl=en (“How Google uses cookies in advertising “)
https://adssettings.google.com/authenticated (“Manage information Google uses to serve ads to you”).
2.9. GOOGLE TAG MANAGER
We use Google Tag Manager on our website. Google Tag Manager is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is used exclusively as a technical management tool to integrate, manage and control website tags. The service itself does not independently analyse user behaviour, create user profiles or carry out advertising or tracking measures.
Google Tag Manager is loaded when the website is accessed in order to ensure the technically reliable integration and management of consent-based services. In this context, technical connection data (such as IP addresses) may be transmitted to Google as part of the provision of the service. Google Tag Manager itself does not store cookies on the user’s end device and does not access information stored there.
Any processing of personal data via services integrated through Google Tag Manager (e.g. analytics or marketing services) takes place exclusively after the user has granted the respective consent via our consent management platform.
The use of Google Tag Manager as a technical tool is based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the efficient, secure and technically reliable operation of our website.
Further information about Google Tag Manager can be found at:
2.10. DOUBLECLICK BY GOOGLE
The DoubleClick service provided by Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) uses cookies to display relevant advertisements. These cookies enable Google and its partners to show ads based on users’ previous visits to our website and other websites on the internet.
You can deactivate the use of DoubleClick cookies by adjusting your browser settings or by using Google’s ad settings tool:
https://adssettings.google.com/
Further information on Google’s advertising data processing can be found in Google’s privacy policy:
https://policies.google.com/technologies/ads