Privacy policy

1. Data protection at a glance

General information

This is a convenience translation; only the German version is legally binding. The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. Detailed information on the subject of data protection can be found in our privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. The operator's contact details can be found in the section “Information about the controller” in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, when you provide it to us. This may be, for example, data that you enter in a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is mainly technical data (e.g. web browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the data transmitted will also be processed for contract offers, orders or other order enquiries.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you can revoke this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time about this and any other questions on the subject of data protection.

Analytics tools and third-party tools

When you visit this website, your browsing behaviour may be statistically analysed. This is done primarily with so-called analytics programs.

Detailed information on these analytics programs can be found in the following privacy policy.

2. Hosting

We host the content of our website with the following provider:

Hetzner

The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter “Hetzner”).

For details, please refer to Hetzner's privacy policy: https://www.hetzner.com/de/legal/privacy-policy/.

Hetzner is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information about the controller

The controller responsible for data processing on this website is:

APRO Kassensysteme GmbH
Marktstraße 19/7
A-3312 Oed-Oehling

Phone: +43 (0)7472/674 03
Phone (Germany): +49 (0)761/600 465 01
Fax: +43 (0)7472/674 03-4
Email: office@apro.at

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage period

Unless a more specific storage period has been stated in this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a justified request for erasure or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons cease to apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), data processing is additionally based on § 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data on the basis of Art. 6(1)(c) GDPR if it is required to fulfil a legal obligation. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Data protection officer

We have appointed a data protection officer.

APRO Kassensysteme GmbH
Marktstraße 19/7
A-3312 Oed-Oehling

Andreas Rohregger
Email: andreas.rohregger@apro.at
Phone: 0676/4856444

Recipients of personal data

In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the disclosure of data. When using processors, we only disclose our customers' personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint controllership agreement is concluded.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Access, rectification and erasure

Within the framework of the applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to rectification or erasure of this data. You can contact us at any time about this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to promotional emails

We hereby object to the use of contact data published in connection with the legal notice obligation for sending unsolicited advertising and information material. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example through spam emails.

4. Data collection on this website

Cookies

Our website uses so-called “cookies”. Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services provided by third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies for measuring web audiences) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version
Operating system used
Referrer URL
Host name of the accessing computer
Time of the server request
IP address

This data is not combined with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be recorded.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiries by email, telephone or fax

If you contact us by email, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The data you send us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Communication via WhatsApp

For communication with our customers and other third parties, we use, among other things, the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the content of the communication. However, WhatsApp does gain access to metadata generated in the course of the communication process (e.g. sender, recipient and time). We would also like to point out that, according to its own statements, WhatsApp shares personal data of its users with its US-based parent company Meta. Further details on data processing can be found in WhatsApp's privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

WhatsApp is used on the basis of our legitimate interest in communicating as quickly and effectively as possible with customers, prospective customers and other business and contractual partners (Art. 6(1)(f) GDPR). If appropriate consent has been requested, data processing is carried out exclusively on the basis of the consent; this can be revoked at any time with effect for the future.

The communication content exchanged between you and us on WhatsApp will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/7735.

We use WhatsApp in the “WhatsApp Business” version.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://www.whatsapp.com/legal/business-data-transfer-addendum.

We have configured our WhatsApp accounts so that no automatic data synchronisation takes place with the address book on the smartphones in use.

Cognito Forms

We have integrated Cognito Forms into this website. The provider is Cognito LLC, 1310 Gadsden St, Suite 100 Columbia, SC 29201.

Cognito Forms enables us to create online forms in order to record messages, enquiries and other input from our website visitors in a structured manner. All entries you make are processed on the servers of Cognito Forms.

Cognito Forms is used on the basis of our legitimate interest in determining your request in the most user-friendly way possible (Art. 6(1)(f) GDPR). If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

The data you enter in the form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Further information can be found in the privacy policy: https://www.cognitoforms.com/legal/privacy.

5. Analytics tools and advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies into our website. Google Tag Manager itself does not create user profiles, does not store cookies and does not carry out any independent analyses. It only serves to manage and deliver the tools integrated via it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google's parent company in the United States.

Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on its website. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Google Analytics

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used and the user's origin. This data is assigned to the user's respective device. It is not assigned to a user ID.

Furthermore, with Google Analytics we can, among other things, record your mouse and scroll movements and clicks. Google Analytics also uses various modelling approaches to supplement the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to a Google server in the USA and stored there.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://business.safety.google/adscontrollerterms/sccs/.

IP anonymisation

Google Analytics IP anonymisation is activated. As a result, your IP address is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website use and internet use. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.

Browser plugin

You can prevent Google from collecting and processing your data by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

For more information on how Google Analytics handles user data, please see Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Data processing agreement

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Google Analytics e-commerce measurement

This website uses the “e-commerce measurement” function of Google Analytics. With the help of e-commerce measurement, the website operator can analyse the purchasing behaviour of website visitors in order to improve its online marketing campaigns. Information such as orders placed, average order values, shipping costs and the time from viewing to purchasing a product is recorded. This data may be combined by Google under a transaction ID assigned to the respective user or their device.

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising programme of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed on the basis of user data available to Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to our advertisements being displayed and how many advertisements led to corresponding clicks.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.

Google Ads Remarketing

This website uses the functions of Google Ads Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads Remarketing, we can assign people who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Ads Remarketing can be linked to Google's cross-device functions. In this way, interest-based, personalised advertising messages that have been tailored to you depending on your previous usage and browsing behaviour on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have a Google account, you can object to personalised advertising at the following link: https://adssettings.google.com/anonymous?hl=de.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Further information and the data protection provisions can be found in Google's privacy policy at: https://policies.google.com/technologies/ads?hl=de.

Meta Pixel (formerly Facebook Pixel)

To measure conversions, this website uses the visitor action pixel from Meta. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta, however, the collected data is also transferred to the USA and other third countries.

This allows the behaviour of site visitors to be tracked after they have been redirected to the provider's website by clicking on a Meta advertisement. This enables the effectiveness of Meta advertisements to be evaluated for statistical and market research purposes and future advertising measures to be optimised.

The data collected is anonymous to us as the operator of this website; we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Meta so that a connection to the respective user profile on Facebook or Instagram is possible and Meta can use the data for its own advertising purposes in accordance with the Meta Data Policy (https://de-de.facebook.com/about/privacy/). This enables Meta to display advertisements on Facebook or Instagram and other advertising channels. We as the site operator cannot influence this use of the data.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

We use the advanced matching function within the Meta Pixel.

Advanced matching allows us to transmit various types of data (e.g. place of residence, state, postcode, hashed email addresses, names, gender, date of birth or telephone number) of our customers and prospective customers that we collect via our website to Meta. This allows us to tailor our advertising campaigns on Facebook and Instagram even more precisely to people who are interested in our offers. In addition, advanced matching improves the attribution of website conversions and expands Custom Audiences.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Meta, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are joint controllers for this data processing (Art. 26 GDPR). The joint controllership is limited exclusively to the collection of the data and its forwarding to Meta. The processing by Meta that takes place after the forwarding is not part of the joint controllership. The obligations incumbent on us jointly have been set out in a joint controllership agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Meta tool and for the secure implementation of the tool on our website in terms of data protection law. Meta is responsible for the data security of Meta products. You can assert data subject rights (e.g. requests for access) regarding the data processed by Facebook or Instagram directly with Meta. If you assert data subject rights with us, we are obliged to forward them to Meta.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

Further information on protecting your privacy can be found in Meta's privacy notices: https://de-de.facebook.com/about/privacy/.

You can also use the ad settings at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen to deactivate the “Custom Audiences” remarketing function. To do so, you must be logged in to Facebook.

If you do not have a Facebook or Instagram account, you can deactivate usage-based advertising from Meta on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use newsletter service providers, described below, to handle the newsletter.

Mailchimp with success tracking deactivated

This website uses the services of Mailchimp to send newsletters. The provider is The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Mailchimp is a service that can be used, among other things, to organise the sending of newsletters. If you enter data for the purpose of subscribing to the newsletter (e.g. email address), this data is stored on Mailchimp's servers in the USA. We have deactivated success tracking in Mailchimp so that Mailchimp will not analyse your behaviour when opening our newsletters.

If you do not want your data to be transferred to Mailchimp, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

The data you provide to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored by us for other purposes remains unaffected by this.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist is only used for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

For more details, please refer to Mailchimp's privacy policy at: https://mailchimp.com/legal/terms/.

Data processing agreement

7. Plugins and tools

YouTube with privacy-enhanced mode

This website embeds videos from the website YouTube. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of the pages of this website on which YouTube is embedded, a connection to YouTube's servers is established. This tells the YouTube server which of our pages you have visited. If you are logged in to your YouTube account, you enable YouTube to assign your browsing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in privacy-enhanced mode. According to YouTube, videos played in privacy-enhanced mode are not used to personalise browsing on YouTube. Ads played in privacy-enhanced mode are also not personalised. No cookies are set in privacy-enhanced mode. Instead, however, so-called local storage elements are stored in the user's browser, which, similar to cookies, contain personal data and can be used for recognition. Details on privacy-enhanced mode can be found here: https://support.google.com/youtube/answer/171780.

After a YouTube video has been activated, further data processing operations may be triggered over which we have no control.

YouTube is used in the interest of presenting our online offering in an appealing manner. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Further information on data protection at YouTube can be found in its privacy policy at: https://policies.google.com/privacy?hl=de.

Font Awesome (local hosting)

This site uses Font Awesome for the uniform display of fonts. Font Awesome is installed locally. No connection to the servers of Fonticons, Inc. is established in the process.

Further information on Font Awesome can be found in the Font Awesome privacy policy at: https://fontawesome.com/privacy.

Google Maps

This site uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. This service allows us to integrate map material into our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is generally transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google may use Google Fonts for the purpose of uniformly displaying fonts. When you access Google Maps, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

Google Maps is used in the interest of presenting our online offering in an appealing manner and making the locations we indicate on the website easy to find. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please see Google's privacy policy: https://policies.google.com/privacy?hl=de.

8. E-commerce and payment providers

Processing of customer and contract data

We collect, process and use personal customer and contract data for the establishment, content design and amendment of our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The customer data collected will be deleted after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.

Data transfer upon conclusion of contracts for online shops, retailers and the shipping of goods

If you order goods from us, we pass on your personal data to the transport company entrusted with delivery and to the payment service provider commissioned with processing the payment. Only the data required by the respective service provider to fulfil its task will be disclosed. The legal basis for this is Art. 6(1)(b) GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures. If you have given your consent pursuant to Art. 6(1)(a) GDPR, we will pass on your email address to the transport company entrusted with delivery so that it can inform you by email about the shipping status of your order; you can revoke your consent at any time.

9. Audio and video conferencing

Data processing

We use online conferencing tools, among other things, to communicate with our customers. The specific tools we use are listed below. If you communicate with us by video or audio conference via the internet, your personal data will be collected and processed by us and the provider of the respective conferencing tool.

The conferencing tools collect all data that you provide/use to use the tools (email address and/or your telephone number). Furthermore, the conferencing tools process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required to handle the online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

If content is exchanged, uploaded or otherwise made available within the tool, it is also stored on the servers of the tool providers. Such content includes in particular cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.

Please note that we do not have full influence over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. Further information on data processing by the conferencing tools can be found in the privacy policies of the respective tools used, which we have listed below this text.

Purpose and legal bases

The conferencing tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.

Storage period

The data collected directly by us via the video and conferencing tools will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data stored by the operators of the conferencing tools for their own purposes. For details, please contact the operators of the conferencing tools directly.

Conferencing tools used

We use the following conferencing tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.

Data processing agreement

10. Our own services

Handling of applicant data

We offer you the opportunity to apply to us (e.g. by email, by post or via an online application form). Below, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that the collection, processing and use of your data will be carried out in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

Scope and purpose of data collection

If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general contract initiation) and – if you have given your consent – Art. 6(1)(a) GDPR. Consent can be revoked at any time. Within our company, your personal data will only be passed on to persons involved in processing your application.

If the application is successful, the data you have submitted will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship.

Data retention period

If we are unable to offer you a position, you decline a job offer or you withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. Retention serves in particular as evidence in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further retention no longer applies.

Longer retention may also take place if you have given your consent (Art. 6(1)(a) GDPR) or if statutory retention obligations prevent deletion.

Inclusion in the applicant pool

If we do not make you a job offer, it may be possible to include you in our applicant pool. If you are included, all documents and information from the application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.

Inclusion in the applicant pool is based exclusively on your express consent (Art. 6(1)(a) GDPR). Giving consent is voluntary and has no bearing on the current application process. The data subject can revoke their consent at any time. In this case, the data will be irrevocably deleted from the applicant pool unless there are statutory reasons for retention.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been given.

Our social media profiles

This privacy policy applies to the following social media profiles

Data processing by social networks

We maintain publicly accessible profiles on social networks. The individual social networks we use can be found below.

Social networks such as Facebook, X, etc. can generally analyse your user behaviour comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media profiles triggers numerous processing operations relevant to data protection. In detail:

If you are logged in to your social media account and visit our social media profile, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, however, your personal data may also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media profile. If you have an account with the respective social network, interest-based advertising can be displayed on all devices on which you are or were logged in.

Please also note that we cannot trace all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policies of the respective social media portals.

Legal basis

Our social media profiles are intended to ensure the most comprehensive presence possible on the internet. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which are to be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6(1)(a) GDPR).

Controller and assertion of rights

If you visit one of our social media profiles (e.g. Facebook), we and the operator of the social media platform are joint controllers for the data processing operations triggered during this visit. You can in principle assert your rights (access, rectification, erasure, restriction of processing, data portability and complaint) both against us and against the operator of the respective social media portal (e.g. against Facebook).

Please note that, despite joint controllership with the social media portal operators, we do not have full influence over the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.

Storage period

The data collected directly by us via the social media profile will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular retention periods – remain unaffected.

We have no influence on the storage period of your data stored by the operators of the social networks for their own purposes. For details, please obtain information directly from the operators of the social networks (e.g. in their privacy policies, see below).

Your rights

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to object, the right to data portability and the right to lodge a complaint with the competent supervisory authority. Furthermore, you can request the rectification, blocking, erasure and, under certain circumstances, the restriction of the processing of your personal data.

Individual social networks

Facebook

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter “Meta”). According to Meta, the collected data is also transferred to the USA and other third countries.

We have concluded a joint controllership agreement (Controller Addendum) with Meta. This agreement specifies which data processing operations we or Meta are responsible for when you visit our Facebook page. You can view this agreement at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

You can adjust your advertising settings yourself in your user account. To do so, click on the following link and log in: https://www.facebook.com/settings?tab=ads.

For details, please refer to Facebook's privacy policy: https://www.facebook.com/about/privacy/.

Instagram

We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Details of how Instagram handles your personal data can be found in Instagram's privacy policy: https://privacycenter.instagram.com/policy/.

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you would like to deactivate LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Data transfers to the US are based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

Details of how LinkedIn handles your personal data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details of how YouTube handles your personal data can be found in YouTube's privacy policy: https://policies.google.com/privacy?hl=de.

11. APRO online modules

APRO offers various online modules that process personal data.

11.1 APRO user account management

Purpose: Management of the created user profile. APRO offers a mobile application in which various functions can be used. To do so, users must register with an email address and password or their Facebook login details and receive a profile account. In this profile account, the user can view content data on the functions they use at any time and collect reward and status points (loyalty) by scanning the receipt after visiting a restaurant. Based on the turnover on the receipt or the respective products, reward and status points are credited to the registered user's profile account. Each restaurateur can individually award, manage and incentivise reward points (e.g. through percentage discounts or free items); status points are awarded by the client. Redemption takes place on a subsequent visit by generating an alphanumeric code, which must be given to the waiter taking the order. The discount or item is then automatically unlocked in the ordering system.

To request erasure, you can send an email to info@apro.at or a letter to APRO Kassensysteme GmbH, Marktstraße 19/7, A-3312 Oed-Oehling. Please note that we require further identification data from you for such requests (e.g. passport, identity card, etc.) to ensure that only you can request the erasure of your personal data.

Legal basis: Consent (Art. 6(1)(a) GDPR), performance of a contract, necessary for the implementation of pre-contractual measures (Art. 6(1)(b) GDPR), legitimate interest, in particular defence, exercise and assertion of legal claims (Art. 6(1)(f) GDPR)

The following data is processed: Master data

Storage period: The data may be retained until the end of the third year after the last contact with the client, unless longer contractual or statutory retention periods apply.

11.2 APRO Online-Order (pre-ordering, table ordering, voucher ordering)

Purpose: APRO Online-Order is used to place food and drink orders via smartphone or webshop. The registered user has the option of ordering food and drinks with their smartphone before visiting a restaurant. To do so, the user must register. The registered user can then scroll through the virtual menu and add the desired items to their “shopping basket”. To place the order, the registered user must select one of the payment options (cash, credit card, PayPal or Sofortüberweisung) to complete the transaction. On site, the registered user must identify themselves using a collection code.

The following data is processed: Master data

Storage period: The data may be retained until the end of the third year after the last contact with the client, unless longer contractual or statutory retention periods apply.