Privacy policy
and consents

Table of contents
1. Objective and data controller
2. Basic information on data processing
3. Processing of personal data
4. Recording access data
5. Cookies and reach measurement
6. Google Analytics
7. Google re/marketing services
8. Facebook social plugins
9. Facebook remarketing
10. Newsletter
11. Integrating services and third-party content
12. User rights and deletion
13. Changes to the privacy policy
14. Disclosure of personal data to third parties

1. Objective and data controller

This privacy policy explains the nature, scope and purpose of the processing (including collection, processing and use, and obtaining consent) of personal data within our online offer and the associated websites, functions and content (hereinafter collectively referred to as “Online Offer” or “Website”). The privacy policy applies irrespective of the domains, systems, platforms and devices used (e.g. desktop or mobile) on which the Online Offer is implemented.

The provider of the Online Offer and the controller under data protection law is [company_name], owner: Gebietsvinothek Weinviertel GmbH, Hauptplatz 4-5, 2070 Retz (hereinafter referred to as “Provider”, “We” or “Us”). For contact options, We refer the reader to our legal notice.

The term “user” includes all customers of and visitors to our Online Offer. The terms used, such as “user”, should be understood as gender-neutral.

2. Basic information on data processing

We also adhere to the relevant data protection provisions when processing our users’ personal data and do so in accordance with the imperative to minimise and avoid data use. This means that user data are processed solely under statutory licence, in particular when the data are required for the provision of our contractual and online services or are prescribed by law or processed with consent.

We take organisational, contractual and technical security measures in line with the state of the art to ensure that the provisions of data protection regulations are observed and to protect the data We process from accidental or intentional manipulation, loss, destruction or access by unauthorised parties.

Where contents, tools or other means of other providers (hereinafter referred to jointly as “Third-Party Providers”) whose designated registered office is in another country are used in the context of this privacy policy, it should be assumed that a data transfer to the state of registration of the Third-Party Provider will take place. The transfer of data to third countries will take place either on the basis of a statutory licence, user consent or special contractual clauses which guarantee data security as a legal condition.

3. Processing of personal data

The personal data will be used, in addition to those purposes expressly stated in this privacy policy, for the following purposes based on statutory licence or user consent:
– The provision, execution, maintenance, optimisation and safeguarding of our services and user benefits;
– The guarantee of effective customer service and technical support.

We will transfer user data to third parties only if to do so is required for invoicing purposes (e.g. to a payment service provider) or for other purposes if these are required for the fulfilment of our contractual obligations to the users.

When a user contacts Us (using the contact form or by e-mail), the user’s information is stored for the purpose of processing the request and for the event that subsequent questions arise.
Personal data are deleted once they have fulfilled their purpose and no retention obligations stand in the way of their deletion.

4. Recording access data

We record access data concerning every access to the server on which this service is located (server log files). The access data include the name of the website accessed, the file, date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page), the IP address and the requesting provider.

We use the log data in accordance with the legal provisions without attributing them to the person of the user or undertaking profiling in any other way only for statistical analysis for the purpose of the operation, security and optimisation of our Online Offer. We reserve the right, however, to inspect the protocol data if there are concrete indications which justify a suspicion of unlawful use.

5. Cookies and reach measurement

Cookies are pieces of information that are transmitted from our web server or third-party web servers to users’ web browsers, where they are stored for later retrieval. The users are informed in this privacy policy about the use of cookies in the context of pseudonymised reach measurement.

This Online Offer may be viewed even if the use of cookies is excluded. If users do not wish cookies to be stored on their computer, We would ask them to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the browser system settings. The exclusion of cookies can result in impairments to the functioning of this Online Offer.

It is possible to manage many online ad cookies from companies via the US site http://www.aboutads.info/choices or the EU site http://www.youronlinechoices.com/uk/your-ad-choices/.

6. Google Analytics

We use Google Analytics, a web analysis service provided by Google Ireland Ltd. (“Google”). Google uses cookies. The information generated by the cookie about the use of the Online Offer by the user is generally transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf for the purpose of evaluating your use of our Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In the process, pseudonymous usage profiles of the users can be generated from the processed data.

We use Google Analytics only with active IP anonymisation. This means that user IP addresses are truncated by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional situations will the full IP address be transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection by Google of the data generated by the cookie and related to their use of the Online Offer and the processing thereof by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

For more information on Google’s use of data for advertising purposes, settings and opt-out 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”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage the information Google uses to show you ads”) and http://www.google.com/ads/preferences (“Determine what ads Google shows you”).

7. Google re/marketing services

We use the marketing and remarketing services (in short: “Google marketing services”) of Google Ireland Ltd., Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, (“Google”).

The Google marketing services allow us to display advertising for and on our Website in a more targeted manner to present users with adverts which might match their interests. Where users are shown adverts for products in which they have shown interest on other websites, this is known as “remarketing”. For these purposes, when our Website and other websites on which Google marketing services are active are called up, a code from Google is executed directly by Google and remarketing tags (invisible graphics or code, also known as web beacons) are integrated into the website. With their aid, an individual cookie, i.e. a small file, is stored on the device (similar technologies can also be used in place of cookies). The cookies can be placed by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. In this file, information is stored as to which websites the user has visited, which content they have shown interest in and which offers they have clicked on, as well as technical information about the browser and operating system, referring websites, time of visit and other information on the use of the Online Offer. The user’s IP address is also recorded; however, we inform you in the context of Google Analytics that the IP address is truncated within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only transferred in full to a Google server in the USA and truncated there in exceptional cases. The IP address will not be merged with user data in other Google services. The information mentioned in the foregoing can also be associated with such information from other sources. If the user proceeds to visit other websites, they may be shown targeted adverts which correspond with their interests.

User data are processed in pseudonymised form in the context of Google marketing services. This means that Google does not, for example, store and process the names or e-mail addresses of users; instead it processes the relevant data in a cookie-related manner within pseudonymised user profiles. This means that, from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This will not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information about the users collected by “DoubleClick” will be transmitted to Google and stored on Google servers in the USA.

The Google marketing services We use include the online advertising program known as “Google AdWords”. In the case of Google AdWords, every AdWords customer receives a conversion cookie. Cookies can thus not be tracked via the websites of AdWords customers. The information obtained with the aid of the cookie serves to generate conversion statistics for AdWords customers who have opted for conversion tracking. The AdWords customers get to see the total number of users who have clicked on their ads and been forwarded to a site furnished with a conversion tracking tag. They do not, however, receive any information which might be used to personally identify users.

We integrate third-party ads on the basis of the “DoubleClick” Google marketing service. DoubleClick uses cookies which enable Google and its partner websites to display ads on the basis of user visits to this website or other websites on the Internet.

We also integrate third-party ads on the basis of the “AdSense” Google marketing service. AdSense uses cookies which enable Google and its partner websites to display ads on the basis of user visits to this website or other websites on the Internet.

Another Google marketing service which We use is the “Google Tag Manager”, with the aid of which further Google analysis and marketing services can be integrated into our Website (e.g. “AdWords”, “DoubleClick” or “Google Analytics”).

For more information about Google’s use of data for marketing purposes, see the overview page: https://www.google.com/policies/technologies/ads; Google’s privacy policy is available to view at https://www.google.com/policies/privacy.

If you wish to block the recording of information by Google marketing services, you can use the setting and opt-out options provided by Google: http://www.google.com/ads/preferences.

8. Facebook social plugins

Our Online Offer uses social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins are recognisable by one of the Facebook logos (a white “f” on a blue tile, the word “Like” or a “thumbs up” sign) or are tagged with the words “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

When a user clicks on a function of this Online Offer which contains this kind of plugin, their device will establish a direct connection with Facebook’s servers. The content of the plugin will be transmitted directly to the user’s device by Facebook and integrated by the device into the Online Offer. In the process, usage profiles of the users can be generated from the processed data. We thus have no influence on the scope of the data collected by Facebook with the aid of the plugin and therefore inform our users in accordance with the state of our knowledge.

The integration of the plugin gives Facebook the information that a user has visited the corresponding page of the Online Offer. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information will be transmitted from their device directly to Facebook and stored there. Even if a user does not have a Facebook account, the possibility nonetheless exists that Facebook will acquire knowledge of and store their IP address. According to Facebook, only anonymised IP addresses are stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

If a user has a Facebook account and does not want Facebook to collect data about them via this Online Offer and link it to their account data as stored by Facebook, they must log out of Facebook and delete their cookies before using our Online Offer. Further settings and the registration of objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. These settings are not platform-specific, i.e. they can be changed for all devices, such as desktop computers or mobile devices.

9. Facebook remarketing

In our Online Offer, “Facebook pixels” from the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), are used. With the aid of the Facebook pixel, Facebook can identify visitors to our Online Offer as a target group for the presentation of ads, known as “Facebook ads”. Accordingly, We use the Facebook pixel to display the Facebook ads placed by Us only to those Facebook users who have also shown an interest in our Website. This means that We want to use the Facebook pixel to ensure that our Facebook ads correspond to the potential interests of our users and are not perceived as harassment. With the help of the Facebook pixel, We can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our Website after clicking on a Facebook ad.

The Facebook pixel is directly integrated by Facebook when our websites are visited and can store a cookie, i.e. a small file, on the user’s device. If the user then logs on to Facebook or visits Facebook when already logged on, their visit to our Online Offer will be noted in their profile. The data collected concerning their person are anonymous for Us, meaning that they offer Us no opportunity to connect them with the identity of users. However, the data are stored and processed by Facebook, with the consequence that it is possible to connect them to the user profile concerned. Any data processing carried out by Facebook is covered by Facebook’s data use policy. Accordingly, the user can glean further information on how the remarketing pixel works and on the presentation of Facebook ads in general from Facebook’s data use policy: https://www.facebook.com/policy.php.

Users can block the recording of data by the Facebook pixel and the use of their data for the presentation to them of Facebook ads. To do so, they can visit the site set up by Facebook and follow the instructions there on the settings for use-based advertising: https://www.facebook.com/settings?tab=ads or declare their objection via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. These settings are not platform-specific, i.e. they can be changed for all devices, such as desktop computers or mobile devices.

10. Newsletter

The following information is intended to provide the user with information about the content of our newsletter as well as the registration, mailout and statistical evaluation procedure and their rights of objection. When a user subscribes to our newsletter, they are declaring their consent to receive the newsletter and the processes described.

Content of the newsletter: We send newsletters, e-mails and other electronic messages with advertising information (hereinafter “Newsletter”) only with the consent of the recipients or statutory licence. Where the contents of the Newsletter are specifically described in the process of subscription, they are crucial for user consent. Our Newsletter otherwise contains the following information: our products, offers, special offers and our company.

Double opt-in and logging: Subscribing to our Newsletter uses the double opt-in procedure. This means that the user receives an e-mail after registering in which they are asked to confirm their subscription. This confirmation is required to ensure that no-one can subscribe using third-party e-mail addresses. Subscriptions to the Newsletter are logged to allow Us to demonstrate that the subscription process complies with the legal requirements. This includes logging the times of subscription and confirmation and the IP address. Also logged are changes to the user’s data stored by the mailing service provider.

Mailing service provider: The Newsletter is mailed out by “Newsletter2go” (hereinafter referred to as “Mailing Service Provider”). The Mailing Service Provider’s privacy policy can be viewed here: Privacy policy.

The e-mail addresses of our Newsletter recipients, as well as other data of those recipients described in this information, are stored on the servers of the Mailing Service Provider. The Mailing Service Provider uses this information to mail out and evaluate the Newsletter in our name. Furthermore, according to its own information, the Mailing Service Provider may use these data to optimise or improve its own services, e.g. for the technical optimisation of the mailout and presentation of the Newsletters or for commercial purposes to determine the countries of origin of the recipients. The Mailing Service Provider does not, however, use the data of our Newsletter recipients to contact them itself or to disclose them to third parties.

Subscription data: To subscribe to the Newsletter it is sufficient for the user just to state their e-mail address.

Statistical collection and analyses – the newsletters contain a web beacon, i.e. a pixel-sized file that is retrieved from the server of the Mailing Service Provider when the Newsletter is opened. In the context of this retrieval, technical information such as information on the browser and your system, including your IP address and the time of retrieval, is initially recorded. This information is used for the technical improvement of the service on the basis of the technical data or target groups and their reading patterns based on their places of retrieval (which can be determined with the aid of the IP address) or access times. Also included in the collection of data for statistical purposes is the determination of whether the Newsletters have been opened, when they were opened and which links have been clicked on. It is the case that this information can, for technical reasons, be matched with individual Newsletter recipients. However, neither We nor the Mailing Service Provider have any intention of monitoring individual users. Instead, these evaluations help Us identify the reading habits of our users and to adjust our content to their preferences or send various contents in accordance with their interests.

Termination/cancellation – the user can cancel their receipt of our Newsletter at any time i.e. they can withdraw their consent. This will result in the simultaneous revocation of their consent to the despatch of the Newsletter by the Mailing Service Provider and the statistical analyses. Separate revocation of despatch by the Mailing Service Provider or statistical evaluation is unfortunately not possible. The user will find a an unsubscribe link for the Newsletter at the bottom of every Newsletter.

11. Integrating services and third-party content

It can occur that contents or services of third parties, such as city maps or fonts from other websites, are integrated in our Online Offer. The integration of third-party provider content always presupposes that the third-party provider has knowledge of the user’s IP address, as it would be unable to send its content to the user’s browser without such knowledge. The IP address is thus required for the presentation of this content. Furthermore, the providers of third-party content can place their own cookies and process user data for their own purposes. In the process, usage profiles of the users can be generated from the processed data. We will use these contents with the greatest possible data minimisation and avoidance and with an eye to the data security of reliable third-party providers.

The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, as in part already mentioned here, opt-out options:

– External fonts from Google Inc., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts involves a server call to Google (generally in the USA). Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.

– Maps from the “Google Maps” service of third-party provider Google Ireland Ltd., Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.

– Videos from the YouTube platform of third-party provider Google Ireland Ltd., Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.

12. User rights and deletion of data

Users have the right to obtain information free of charge about the personal data We hold concerning their person.
Moreover, users have the right to the rectification of incorrect data, the revocation of consents, the blocking and erasure of their personal data and the right, in the event of the acceptance of unlawful data processing, to file a complaint with the competent supervisory body.

The data We hold will be deleted as soon as they are no longer required for the stated purpose and no statutory retention obligations stand in the way of their deletion.

13. Changes to the privacy policy

We reserve the right to change the privacy policy to adapt it to changes in the legislation or to the service or the data processing. This applies, however, only in respect of declarations with regard to data processing. If user consents are required or elements of the privacy policy contain provisions governing the contractual relationship with the users, the changes will take place only with the consent of the users.
The users are requested to keep themselves regularly up to date with the content of the privacy policy.

14. Disclosure of personal data to third parties

Personal data of the buyer will be disclosed to third parties only to the extent required for fulfilment of the contract. Your data will be disclosed to the MoneySoft Softwarevertriebs GesmbH settlement program, Hatzenbach No. 59, 2011 Hatzenbach for the fulfilment of the contract (company, first name, last name, address, postcode, town or city, phone, e-mail). Moneysoft’s privacy policy.

Other companies will receive your personal data from the provider for the fulfilment of the contract. Despatch settlement for our German customers via Kurt Müller Weinexport GmbH, Fasanenweg 1, 88213 Ravensburg, Germany. (company, first name, last name, address, postcode, town or city)

Any further disclosure of the user’s personal data will be considered only if there is a legal obligation to do so or if it is necessary to enforce the rights of Newsletter2Go, in particular to enforce claims arising from the contractual relationship.

Last revised: 18 July 2019