In accordance with Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”) and the Austrian Data Protection Act (DSG), Inspiralia GmbH processes the Customer’s personal data for the proper performance of the contractual relationship, sends commercial/advertising communications based on the Customer’s commercial profile about products and/or services related to the effectively concluded contracts, as well as about financial services, technical and business consulting services, services of intermediation and commercial development, development of products and technological applications, as well as consulting services and intermediation in the search for financial resources. This processing is legitimized on the basis of the signing of this contract and the legitimate interest of Inspiralia Ltd in maintaining the business relationship. The data will be kept for as long as this relationship lasts and beyond, until the possible liabilities resulting from it have lapsed.In addition, the data of all the signatories of this service and consultancy contract belonging to the Customer (the “Signatories”) may be transferred to other companies of the Inspiralia Group, such as Tecnologías Avanzadas Inspiralia SL, Toro Ventures Financial and Management Services SL, Future Sense SL, Fen Technology Ltd and Inspiralia USA Inc (which in the latter case would constitute an international transfer of its data to the USA). The adequate level of protection is derived from an adequacy decision of the European Commission under Art 45 GDPR. The undersigned may exercise their rights of access, rectification, erasure, opposition, restriction and portability of their data at any time and may request this in writing by sending an email to dach@inspiralia.com. The customer has the right to file a complaint with the Austrian Data Protection Authority (Barichgasse 40-42, 1030 Vienna). (according to §24 para. 1 DSG).
Likewise, during the provision of the services, the parties may have access to personal data for which the Customer is responsible. In this context, with regard to compliance with the regulations on the protection of personal data, Inspiralia GmbH as the data processor, whereby Inspiralia GmbH undertakes to comply with the DSGVO and to ensure that the parties undertake as follows:a) The processing of personal data is carried out exclusively for the purpose of fulfilling the contractual services and adapting to the instructions of the customer.
b) To maintain confidentiality in respect of all personal data to which access is given, this obligation continuing after termination of the contractual relationship for whatever reason, and to ensure that all persons providing services to Inspiralia GmbH have undertaken to comply with this obligation.
c) Ensuring a level of security appropriate to the risk, taking into account the state of the art and its nature, the scope and context, and the purposes of the processing, as well as any risks of likelihood and significance for the rights and freedoms of data subjects for which they must implement appropriate technical and organizational measures. In assessing the adequacy of the level of security, Inspiralia GmbH shall take into account the ability to ensure the continued confidentiality, integrity, availability and resilience of processing systems and services, in particular as a result of the accidental or unlawful destruction, loss or alteration of, or unauthorized disclosure of or access to, personal data transmitted, stored or otherwise processed.
d) not to disclose personal data to third parties (except for the Inspiralia Group companies mentioned in point 1, investors and relevant funding bodies), including for the purpose of onward transfer, and not to disclose it to persons who are not members of the Inspiralia Group without prior written consent. In all cases where Inspiralia GmbH has to assign another service provider to access the data (sub-processor), Inspiralia GmbH has to identify the third party in advance (name, address), and this can only be done with the express prior written consent of the customer.
e) Upon written request of the Data Controller, how to delete or return all personal data to which Inspiralia GmbH had access in order to provide the Service or to fulfill its obligations under this Contract. In this case, Inspiralia GmbH undertakes to destroy all existing copies, except in cases where there is a provision requiring their retention and/or where it proves necessary in order for Inspiralia GmbH to fulfill its contractual obligations and enforce its own contractual claims, in which case retention shall be reasonably limited.
Below is an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or headquarters may also apply. If specific legal bases are applicable in individual cases, we will inform you about these in the privacy policy.
In addition to the data protection regulations of the GDPR, national regulations on data protection in Austria apply. This includes, in particular, the Federal Act on the Protection of Natural Persons with Regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains specific provisions regarding the right to access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes, data transfers, and automated decision-making in individual cases.
In accordance with legal requirements, and taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, availability of, and separation of the data. Additionally, we have implemented procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data security threats. Furthermore, we incorporate data protection principles in the design and selection of hardware, software, and procedures, adhering to the principles of data protection by design and by default.
To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data against unauthorized access.
TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as a signal to users that their data is being transmitted securely and in encrypted form.
In the course of processing personal data, it may occur that such data is transferred to other entities, companies, legally independent organizational units, or individuals, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT-related duties or providers of services and content integrated into a website.
In such cases, we adhere to the legal requirements and, in particular, enter into appropriate agreements or contracts with the recipients of your data to ensure the protection of your personal data.
We delete personal data we process in accordance with legal requirements as soon as the underlying consent is revoked or no further legal basis for processing exists. This applies to cases where the original purpose of the processing is no longer applicable or the data is no longer needed. Exceptions to this rule arise if legal obligations or specific interests necessitate longer retention or archiving of the data.
Data that must be retained for commercial or tax purposes, or whose storage is necessary for legal prosecution or the protection of the rights of other natural or legal persons, will be archived as required.
Our privacy policy provides additional information regarding data retention and deletion for specific processing activities.
If multiple retention periods or deletion deadlines are specified for certain data, the longest period always takes precedence.
Data that is no longer retained for its original purpose but due to legal requirements or other reasons will only be processed for the reasons that justify its retention.
As a data subject, you are entitled to various rights under the GDPR, particularly those outlined in Articles 15 to 21. These rights are as follows:
By exercising these rights, you help ensure the proper handling of your personal data and compliance with data protection laws.
We process users’ data to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functionalities of our online services to the user’s browser or device.
For the provision of our online services, we use storage space, computing capacity, and software rented or otherwise obtained from a corresponding server provider (also referred to as a “web host”).
Access to our online services is logged in the form of “server log files.” These files may include the address and name of the retrieved websites and files, the date and time of retrieval, the amount of data transferred, success messages, browser type and version, the user’s operating system, referrer URL (previously visited page), and typically IP addresses and the requesting provider.
Cookies refer to functions that store and read information on users’ devices. They can serve various purposes, such as enabling the functionality, security, and comfort of online services, as well as analyzing visitor traffic. We use cookies in compliance with legal requirements and, when necessary, obtain user consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online services. Consent can be revoked at any time, and we provide clear information about the scope and types of cookies used.
Whether we process personal data through cookies depends on user consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as explained in this section and in the context of specific services and procedures.
Cookies are distinguished by their retention period:
Users can withdraw their consent at any time and also object to the processing of their data in accordance with legal requirements, including through their browser’s privacy settings.
We use a consent management solution to collect users’ consent for the use of cookies or for processes and providers specified within the solution. This procedure is used to obtain, record, manage, and withdraw consent, particularly for the use of cookies and similar technologies that store, read, and process information on users’ devices.
Through this process, users’ consent is obtained for the use of cookies and the associated data processing, including specific processes and providers mentioned in the consent management solution. Users can also manage and revoke their consent. The consent declarations are stored to avoid repeated requests and to meet legal documentation requirements. The storage occurs server-side and/or in a cookie (known as an opt-in cookie) or using similar technologies, allowing us to associate the consent with a specific user or device.
Unless specific details are provided about the providers of consent management services, the following general information applies:
When contacting us (e.g., via mail, contact forms, email, phone, or social media), as well as in the context of existing user and business relationships, the details of the inquiring persons are processed as far as necessary to respond to the contact inquiries and any requested actions.
When contacting us through our contact form, email, or other communication methods, we process the personal data provided to respond to and address the respective matter. This typically includes information such as name, contact details, and any other information provided that is necessary for appropriate handling. We use this data exclusively for the stated purpose of communication and response.
Web analytics (also referred to as “reach measurement”) is used to evaluate the visitor traffic on our online services. It may include pseudonymous data on visitor behavior, interests, or demographic information, such as age or gender. With reach analysis, we can, for example, determine when our online offerings or their functions and content are most frequently used, or encourage return visits. It also helps us identify areas for optimization.
In addition to web analytics, we may also employ testing methods, such as A/B testing, to test and optimize different versions of our online offerings or its components.
Unless otherwise specified below, profiles—data aggregated during a usage process—may be created, and information may be stored and retrieved from a browser or device. The collected data may include visited websites, elements used on those websites, as well as technical details such as browser type, operating system, and usage times. If users have consented to the collection of their location data either directly to us or to the providers of services we use, location data may also be processed.
Additionally, the IP addresses of users are stored. However, we employ an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect the users. Generally, for web analytics, A/B testing, and optimization, no clear user data (such as email addresses or names) is stored. Only pseudonymous data is kept, meaning neither we nor the service providers of the tools know the actual identity of the users but only the data stored in their profiles for the purposes of the respective processes.
Matomo is a software used for web analytics and reach measurement. The data collected through Matomo is processed solely by us and not shared with third parties. Cookies are created and stored on users’ devices during Matomo usage. These cookies have a maximum retention period of 13 months.
This refers to the hosting of the Matomo web analytics and reach measurement software.
We maintain online presences within social networks and process user data in this context to communicate with active users or offer information about ourselves.
We would like to point out that user data may be processed outside the European Union. This could pose risks to users, as it may become more difficult to enforce user rights.
Furthermore, user data within social networks is typically processed for market research and advertising purposes. For example, usage behavior and resulting interests can be used to create user profiles. These profiles may then be used to display ads within and outside of the networks that are presumed to align with the user’s interests. Cookies are typically stored on users’ devices to track usage behavior and interests. Additionally, user profiles can store data independent of the devices used by the users (especially if they are members of the platforms and logged in there).
For a detailed explanation of the specific forms of processing and opt-out options, we refer to the privacy policies and statements of the respective network operators.
Even in the case of data requests and asserting rights of the data subjects, we recommend addressing these issues to the providers themselves. Only the providers have access to the user data and can directly take appropriate actions and provide information. However, if you still need assistance, you can contact us.
We kindly ask you to regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you when these changes require any action from your side (e.g., consent) or when any individual notification is necessary.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that these addresses may change over time. We recommend verifying the information before contacting us.
In this section, we provide an overview of the terminology used in this privacy policy. Where terms are legally defined, the legal definitions apply. The following explanations are intended to aid understanding.