PRIVACY POLICY

Protecting your privacy and personal data is very important to us. We therefore only use your personal data within the scope of legal regulations, in particular the General Data Protection Regulation ("GDPR") and the (Austrian) Data Protection Act ("DSG"). This Privacy Policy provides you with information on how EQUINERA GmbH, FN 566293i, Eichkogl 43, A-8322 Eichkoegl, („we“ or “Equinera”) will process your personal data when you use our website or services. 

1. Purposes for which we process your data
We will process your personal data set out in Point 2 below for the following purposes:
a. to fulfil your orders
b. to verify your identity
c. to determine the age of users of a customer account
d. manage and maintain your account with us
e. respond to your questions and comments and provide customer support
f. marketing our business and products to you
g. provide you with information you have requested about our company, our products and our services
h. for internal purposes such as auditing, data analysis and research and development to improve services and products

2. Processed data categories 

The types of personal data we may hold about you include: 
a. Account-Information (name and surname, date of birth, gender)
b. IP-address, name and version of your web-browser
c. Contact information (such as name, postal or email address and phone number, preferred contact method)
d. Payment details (including payment card number, expiration date and billing address) 
e. Shipping information (including shipping address and phone number) 
f. Voice and audio data
g. Information generated by us in the course of our business relationship with you, such as a history of our interactions with you, your purchases from us and information about your use of our products
h. Other Information (such as usage behavior and preferences)

Data collection not from the data subject: 
If you are referred by other users, we might receive your personal data from individuals other than you.

For security and fraud prevention purposes, we may also verify the information you provide when an account for this website is created for third parties.

3. Legal basis for processing personal data
EU Data protection law requires us to have a legal basis before processing any Personal Data about you.  The legal basis for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests of operating and promoting our business.

4. Transfer of your personal data
We intend to keep your Personal Data confidential, in compliance with our legal obligations. For the purpose set out above, we will transfer your personal data to the following recipients: 
Companies that are part of our corporate group
to verify your identity 
in order for us to comply with our legal obligations, e.g. where we are required to disclose certain information to tax authorities
to any of our outsourced vendors, suppliers or distributors to facilitate the provision of contracted services or goods as well as customer service
IT service providers that we use
for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event
to any other third party where you have provided your consent
We may disclose or transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in section 1 above, in particular your personal data may be transferred throughout the Equinera group.  In these circumstances, we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means. You may be entitled under applicable law to receive a copy of the safeguards which we have put in place to protect your personal data and privacy rights; please get in touch with us for further information on how to exercise this right. 

5. Retention of personal data
Your personal data will be retained for the duration of our business relationship and for a period of time thereafter as required by applicable local law or where we have a legitimate and lawful purpose. 

6. Security measures used to protect personal data
Equinera takes the security of your personal data very seriously. We take appropriate physical, technical and organizational security measures designed to safeguard and secure any personal data provided to us.
Notwithstanding our efforts to maintain an appropriately high level of due diligence at all times, it cannot be ruled out that information that you disclose to us via the internet may be viewed and used by other people. 
Please note that we therefore accept no liability whatsoever for the disclosure of information due to errors in data transmission not caused by us and/or unauthorised access by third parties (e.g. hacking attacks on e-mail accounts or telephone).
When you use Equinera’s services or applications or post personal information in chat rooms or social networks, for example, this personal information and content is visible to other users and can be read, collected or used by them. You are solely responsible for the personal information that you share or submit in the process. For example, if you post your name and e-mail address in a forum, this information is public. Use these features with caution.

7. Your rights in connection with your personal data
Under applicable law, you have, among others, the rights (under the conditions set out in applicable law): (i) to check whether and what kind of personal data we hold about you and to request copies of such data, (ii) to request correction, supplementation or deletion of your personal data that is inaccurate or processed in non-compliance with applicable requirements, and (iii) to request us to restrict the processing of your personal data, (iv) in certain circumstances, to object for legitimate reasons to the processing of your personal data or to revoke consent previously granted for the processing, (v) to request data portability, (vi) to know the identities of third parties to which your personal data are transferred, and (vii) to lodge a complaint with the competent authority. 

8. Collection and use of non-personal information
We also collect data in a form that in itself does not allow a direct reference to a specific person. We may collect, use, share and disclose non-personal information for any purpose. Below are some examples of the non-personal information we may collect and store:
information such as occupation, language, postal code, area code, referral websites, location, and time zone of where Equinera services and products are used to analyze customers’ usage behavior to improve our products, service and for advertisements.
detailed information about your use of our services. 
information about your usage of devices and applications.
In case we link non-personal information to personal information, the linked information is treated as personal information as long as it remains linked.

9. Automatically collected information
We collect usage and log information about your activity on our services. This includes information about the services themselves as well as for diagnostic and performance purposes. This implies information about your activity (for example, information about when you registered to use our services, how you use our services, your service settings and the timing, frequency and duration of your activities, your profile, whether you are currently online, when you last used our services, and when you last updated your profile), log files, and diagnostic, crash, website, and performance logs and reports. 
When installing, using or accessing our services, we collect device and connection information. This includes information like hardware model, operating system information, app version, browser information, connection information including phone number, mobile operator or ISP, language and time zone, and IP.
We use cookies to operate and provide our services, including to provide our services that are web-based, improve your experiences, understand how our services are being used, and customize our services. We may also use cookies to remember your choices, like your language preferences, to provide a safer experience, and otherwise to customize our services for you. For further information about how we use cookies to provide you with our services, see item 10 below.

10. Cookies
Equinera’s websites and online services may use "cookies" to make our offer more user-friendly, effective and safer. 
A "cookie" is a small text file that we send via our web server to the cookie file of the browser on the hard disk of your computer. This enables our website and online services to recognize you as a user when a connection is established between our web server and your browser. Cookies help us to determine the frequency of use and the number of users of our website. 
Two types of cookies are used on this website:
Session Cookies: These are temporary cookies that remain in the cookie file of your browser until you leave our website and are automatically deleted at the end of your visit.
Permanent cookies: For improved user-friendliness, cookies remain stored on your terminal device and allow us to recognize your browser the next time you visit us.
You can set your browser so that you are informed about the setting of cookies and allow cookies only 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 you deactivate cookies, the functionality of this website and online services may be limited.

11. Server-Log-Files
In order to optimise the website and online services in terms of system performance, user-friendliness and the provision of useful information about our services, the provider of the website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This includes your Internet Protocol address (IP address), browser and language settings, operating system, referrer URL, your Internet service provider and date/time. 
These data are not merged with personal data sources. We reserve the right to subsequently check this data if we become aware of concrete indications of illegal use.

12. Click through URL
In some e-mail messages to our customers we use a technique called "click through URL". When you click on one of these links, it takes you through our computer system to the actual website you are trying to reach. Equinera uses these "click through URLs" to determine the level of interest in certain topics and to measure the effectiveness of our communication efforts. We do not exchange this information with anyone and we make no attempt to associate the "click through URLs" with individual e-mail addresses. If you do not want such information collected and tracked, do not click on text or graphic links in emails.

13. Our contact details 
Please address your requests or questions concerning the processing of your personal data to: 

Equinera GmbH

Eichkoegl 43

A-8322 Eichkoegl

Austria
Email: compliance.officer@gabineurohr.com

Last update: November 2023