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Data protection

LEGAL INFORMATION & DATA PROTECTION POLICY

Polo Handels GmbH’s Data Protection Policy

A) Visiting our website

1. Who is in charge of handling your personal data?

This privacy policy covers the personal data of visitors, users, prospects, customers and contractual partners of Polo Handels GmbH (hereinafter “we” or “us”).

We are committed to protecting the privacy of our users on this website. This privacy policy sets out in detail what personal data is further used when you use our website and how we protect this data. We only process your data on the basis of the legal regulations (GDPR, TA).

Controller of this website:

Company name: Polo Handels GmbH

Email: dataprivacy@polo-ag.com

Phone: +43 1 712 70 90

Address: Hainburger Straße 34a, A-1030 Wien

2. With whom are we allowed to share your data?

2.1 Data transmission within the Polo Handels GmbH corporation: we may entrust specific data processing steps to specific departments within our corporation. We will do that, for instance, to better process your customer data for internal administration purposes.

2.2 External service providers: we comply with statutory and contractual obligations. In a world of labour division, the required data processing work is oftentimes provided by specialised businesses, so-called service providers (data processors). These businesses can provide such services at attractive rates while delivering high quality. Therefore, we transfer your personal data to such businesses only in the scope necessary for them to provide the contractually agreed services. These services may include data storage in secure computer centres, printing invoices and advertising material, postcards, photos and digitising contracts or invoices (creating a digital, non-editable image). Our data processors include IT service providers, printing service providers, service providers for customer assistance activities, contract management, market research institutes, marketing businesses and advertising agencies.

2.3 Courts and public authorities: there are some statutory provisions that Polo Handels GmbH can only comply with by sharing your necessary personal data with public authorities (such as social security organisations, tax offices or prosecuting bodies, supervisory bodies, customs bodies, health authorities) or courts.

3. May your data also be shared with third parties in another country (including outside the EU)?

3.1 Yes, provided that the European Commission has confirmed that this third country has an adequate data protection level and that adequate data protection guarantees exist (e.g. binding in-house data protection provisions or standard EU data protection clauses).

3.2 Provided that you have given your explicit consent, data may be transferred to a third country (Article 49(1)(a) of the GDPR). This is to inform you about possible risks related to intentional data transfer and a lack of adequate data protection safeguards (item 3.1). On our website, we use, among others, different cookies and similar technologies that we and third-party providers may rely on to process personal data. These third-party providers include Google LLC that are headquartered in the USA where they process their data. The European Court of Justice has declared the data protection level in the USA to be inadequate. It highlighted the risk of your data being accessed by US authorities for control and surveillance purposes and the fact that no effective legal remedies against this exist. Before we place cookies and transfer your data to these companies, we will ask you to provide your explicit consent (Article 6(1)(a) of the GDPR and Article 49(1)(a) of the GDPR) and we will provide detailed information about all data processing (purpose, data categories, and storage period, among others). Information about specific cookies is available here Privacy Overview. You can revoke your consent at any time with future effect. To do that, go to Privacy Overview on our website and change the settings as necessary.

3.3 Given the use of Facebook, data will be transferred to non-EU states. Data transfer is anonymised or pseudo-anonymised.

4. How long will your data be stored?

4.1 As soon as Polo Handels GmbH doesn’t need your personal data anymore for the purposes described above, they will be deleted, unless statutory storage periods to the contrary apply.

4.2 The statutory period of prescription pursuant to the Austrian Civil Code is between three and thirty years. During this time period, claims against Polo Handels GmbH may be brought forward. We may keep your personal data as long as necessary.

4.3 As a result of corporation law provisions (e.g. Federal Fiscal Act, Company Act), your contractual data must be stored for at least seven years after the end of the contractual relationship.

5.What rights do you have?

5.1 If you so desire, we will provide information about your personal data that we process at Polo Handels GmbH whenever you like. In addition, in some cases, you also have the right to data portability, meaning that we would give you all personal data you have disclosed to us in a structured, standard and machine processable format.

5.2 Under certain conditions, you can also demand that the processing of your data is limited or that your personal data is rectified or deleted. In addition, you can object to the processing.

5.3 In some of the previous-mentioned cases, your consent will give Polo Handels GmbH the right to process your data. You can revoke this consent at any time without the need to state reasons with future effect. Until then, we will lawfully process your data.

6. Your right to object

As a data subject, you have the right to object to the use of your data if the processing serves the purpose of direct marketing.

In addition, you have the right to object if reasons arise for you to do so as a result of your particular situation.

7. Legal information and cookie information for websites

7.1. General information

The information provided on the websites of Polo Handels GmbH is for informational purposes only. We take great care to ensure that all information is correct and complete. However, we cannot exclude that unintentional or incidental mistakes will occur.

Polo Handels GmbH is not liable for inaccurate or missing information on its websites. This especially applies, without limitation, to (hyper)links and other content used on our websites directly or indirectly or that can be accessed from them. All decisions based on information provided by Polo Handels GmbH on its websites are the sole and only responsibility of the user.

In addition, Polo Handels GmbH accepts no liability for immediate/specific damage or consequential damage or other damage of any kind that may result in any way from the use of the information (including hyperlinks) provided on its websites.

All above-mentioned provisions also apply to software that can directly or indirectly be accessed or used from the websites of Polo Handels GmbH. If third-party software is accessed via (hyper)links, the rules of the provider in question shall apply.

7.2 Copyright

The design and content of these websites is subject to copyright. Any change or reproduction of images or text from these websites is subject to prior written consent by Polo Handels GmbH. It is explicitly prohibited to use marks (e.g. trademarks, logos).

7.3 Use of cookies

Several parts of our websites rely on cookies and similar technologies (hereinafter referred to as „cookies”). They make our offer more user-friendly and more efficient.

Cookies are small text files on your computer or smartphone and that your browser will store. They usually provide information about what pages/parts of our website were visited by users and can, among others, save user settings so that returning users will be recognised and do not have to log in again. Also, they allow for the targeted displaying of information to users as well as the analysis of website views.

Our business partners, so-called cookie providers, may also place cookies on our websites. These are used to improve our own products and services as if we had placed these cookies ourselves. For instance, to understand how our websites are used, we work with analysis partners including Google and Facebook (for additional information, please see item 9.3.2). However, cookie providers may also rely on cookies used on our websites for their own purposes, e.g. to place (their own or third-party) advertising on our websites and to measure their effectiveness. In such case, Polo Handels GmbH has no influence on the purpose and means of the cookie-based data processing while also not benefiting from this data processing.

7.3.1 Additional information about the advertising functions of Google Inc.

Once we have understood what is important to you and what you are interested in, we can show you relevant and helpful input. To place and manage our ads, we rely on Google Display & Video as well as Google Adwords (Google Ads).

We use the services of Google Ads to place advertising (so-called Google ads) on external websites and highlight our attractive offerings. By linking the data to the advertising campaign, we can determine how successful specific advertising efforts have been. In doing so, we strive to show you advertising that is relevant to you, to make our website more interesting for you and to reach a fair calculation of advertising costs.

These advertising materials are provided by Google via so-called „Ad Servers”. We use Ad Server cookies which measure certain success parameters, including how many times the ads were shown and how many clicks they obtained from users. Provided that you have accessed our website via a Google ad, Google Ads will place a cookie on your device. Such cookies are usually valid for 30 days only and are not used to identify you personally. However, specific users can be grouped via browser recognition.

If you have registered for one of the services provided by Google, Google can link your visit to your account. Even if you have not registered or logged on, the service provider might obtain information about our IP address and save it.

After you have given your consent and made your selection, you can revoke or change these „cookie settings” at any time by going to the cookie management platform.

7.3.2 Additional information about Google Remarketing

In addition to Google Adwords, we use so called Google Remarketing. This is a procedure that we use to target and reach you once again. This application allows us to display our ads on your device after you have visited our website and continue using the Internet. This is done via cookies saved on your browser. These cookies allow Google to identify and analyse your user behaviour when you access different websites. This is how Google can determine that you have previously visited our website. According to information provided by Google, data collected as part of remarketing activities will not be associated with any of your personal data that Google may have saved. Google also highlights that it uses pseudo-anonymization for its marketing activities. For more information about Google’s data protection policy, please visit: https://www.google.com/intl/de/policies/privacy.

After you haven given your consent and made your selection, you can revoke or change these „cookie settings” at any time by going to the cookie management platform.

7.3.3 Additional information about Linkedin, Facebook and Instagram

For the same purpose, i.e. displaying customised ads, Linkedin, Facebook and Instagram Ads may be activated provided that you give your consent. This is not personal information. Personal information will be saved on servers located both in the European Union (Ireland) and in non-EU-States.After you have given your consent and made your selection, you can revoke or change these „cookie settings” at any time by going to the cookie management platform.