Privacy Policy

1. Introduction

In the following, we inform about the processing of personal data when using

  • our website www.keyone.at
  • of our profiles in social media.

Personal data is any data that can be related to a specific natural person, e.g. their name or IP address.

1.1. Contact details

The responsible party according to Art. 4 (7) EU-Datenschutz-Grundverordnung (DSGVO) is Keyone GmbH, Tiergartenstraße 102, 6020 Innsbruck, Österreich, mail: hello@keyone.at.We are legally represented by Moritz Schröcksnadel, Robert Larcher.

Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. The following are generally considered to be the legal basis for data processing:

  • Art. 6 para. 1 p. 1 it. a DSGVO serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 p. 1 lit. b DSGVO is the legal basis insofar as the processing of personal data is necessary for the fulfillment of a contract, e.g. when a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 (1) p. 1 lit. c DSGVO applies if we fulfill a legal obligation with the processing of personal data, as may be the case, for example, in tax law.
  • Art. 6 (1) p. 1 lit. f DSGVO serves as the legal basis when we can invoke legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission (Art. 45 Ab. 3 DSGVO) guarantee the security of the data during the transfer, where available (e.g. for the UK, Canada and Israel).

If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is usually, i.e., unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 (2) lit. b DSGVO, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies want to access data.

1.4. Storage duration

Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5. Rights of the data subjects

Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:

  • Right of information,
  • Right to rectification or deletion,
  • Right to restriction of processing,
  • Right to object to processing,
  • Right to data portability,
  • Right to revoke consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details for the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

In the context of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship, or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7. No automatic decision making in individual cases

For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 DSGVO. Should we use these procedures in individual cases, we will inform you separately if this is required by law.

1.8. Contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f DSGVO) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit f DSGVO. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 (1) p. 1 lit. a DSGVO. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 p. 1 lit. a DSGVO), we also measure the opening and click-through rate of our newsletters to understand which content is relevant to our recipients.

We send newsletters using the tool Numbirds from the provider NumBirds GmbH, Gottfried-Hagen-Str. 22, 51105 Cologne, Germany (privacy policy: https://numbirds.com/datenschutz/). The provider processes content, usage, meta/communication data and contact data in the EU.

3. Data processing on our website

3.1. Informational use of the website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete page)
  • Access status/HTTP status code
  • Data volume transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web hosting and provision of the website

Our website is hosted by All-Inkl.com. The provider is René Münnich ("ALL-INKL.COM - Neue Medien Münnich"), Hauptstraße 68, 02742 Friedersdorf . In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://all-inkl.com/datenschutzinformationen/.

It is our legitimate interest to provide a website, so that the legal basis of the described data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

3.3. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest to answer inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.
We delete the data accruing in this context after the storage is no longer required or restrict the processing if there are legal retention obligations.

3.4. Job position ads

We post jobs that are available within our company on our website, on sites linked to the website, or on third-party websites.
The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 p. 1 lit. a DSGVO).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their resumes and cover letters. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 (2) a DSGVO).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.

We pass on the applicants' data to the responsible employees in the HR department, to our order processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to also use their data for further application procedures, we will not delete their data until one year after receipt of the application.

3.5. Reviews

Site visitors can leave reviews on our website for our goods, services or generally about our company. For this purpose, we process meta data or communication data in addition to the data entered. We have a legitimate interest in receiving feedback from site visitors about our offerings. Therefore, the legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Insofar as we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.6. Customer account

Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of the consent of the site visitor. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. a DSGVO.

Consent can be revoked at any time, e.g. via the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. If consent is revoked, we will delete the data unless we are obliged or entitled to continue storing it.

3.7. Services offer

We offer services via our website. In the process, we process the following data in the context of the order:

  • Name,
  • Address,
  • Fellow travelers,
  • Date of birth,
  • Travel date.

The processing of the data takes place for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 p. 1 lit. b DSGVO).

3.8. Payment service provider

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 DSGVO. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 p. 1 lit. b DSGVO).

These payment service providers are:

  • Klarna Bank AB (publ), Sweden (“Klarna Sofort”)
  • Mastercard Europe SA, Belgium
  • Stripe Payments Europe, Ltd., Ireland
  • Visa Europe Services Inc., UK

3.9. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies for the following purpose or purposes:

  • Cookies that apply language settings,
  • Cookies that remember search terms, cookies that store log-in data, and
  • Flash cookies, which are set to play media content.

4. Data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1. Facebook

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 DSGVO with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.