Privacy Policy

1. Purpose and responsible entity
2. Basic information on data processing
3. Processing of personal data
4. Collection of access data
5. Use of cookies
6. Google Analytics
7. Google Re/Marketing Services
8. Facebook social plug-ins
9. Facebook remarketing
10. Twitter buttons
11. Newsletter
12. Integration of third-party services and content
13. Integration of online forms
14. Web fonts
15. Users' rights and deletion
16. Changes to the privacy policy

1. Purpose and responsible entity
This privacy policy explains the nature, scope and purpose of the processing (including collection, processing and use as well as obtaining consent) of personal data within our online offering and the associated websites, functions and content (hereinafter collectively referred to as “online offer” or “website”). The privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) used on which the online offer is run.

The provider of the online offering and the entity responsible under data protection law is TOP Living GmbH, Salesianergasse 23/19, 1030 Vienna (hereinafter referred to as “provider”, “we” or “us”). For contact options, please refer to our contact details.

The term “user” includes all customers and visitors to our online offer. The terms used, such as “user”, are to be understood as gender-neutral.

2. Basic information on data processing
We process users' personal data only in compliance with the relevant data protection regulations in accordance with the principles of data economy and data prevention. This means that user data will only be processed if there is legal permission, in particular if the data is required to provide our contractual services and online services, or is required by law or if consent has been given.

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

If content, tools or other means from other providers (hereinafter collectively referred to as “third-party providers”) are used within the framework of this data protection declaration and their registered office is abroad, it is assumed that data will be transferred to the home countries of the third-party providers. Data is transferred to third countries either on the basis of legal permission, user consent or special contractual clauses that ensure data security as required by law.

3. Processing of personal data
In addition to the use expressly stated in this privacy policy, personal data is processed for the following purposes on the basis of legal permits or user consent:
— The provision, execution, maintenance, optimization and security of our services, services and user services
— Contact and allocation for any queries
— Ensuring effective customer service and technical support.

We only transfer user data to third parties if this is necessary for billing purposes (e.g. to a payment service provider) or for other purposes if these are necessary to fulfill our contractual obligations to users (e.g. address notification to suppliers).

When contacting us (via contact form or e-mail), the user's details are stored for the purpose of processing the request and in case any follow-up questions arise.
Personal data will be deleted provided that it has fulfilled its intended purpose and the deletion is not precluded by storage obligations.

4. Collection of access data
We collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved website, file, date and time of retrieval, amount of data transferred, message of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

We use the log data without attribution to the person of the user or other profiling in accordance with legal provisions only for statistical evaluations for the purpose of operating, security and optimizing our online offering. However, we reserve the right to review the log data retrospectively if, on the basis of concrete evidence, there is a legitimate suspicion of illegal use.

5. Use of cookies
“Cookies” are small files that are stored on users' devices. Cookies can be used to store various types of information. The information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched.

Cookies are usually also used when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used, for example, to display content to users that match their potential interests. This process is also known as “tracking”, i.e. tracking the potential interests of users. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy.

Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in operating our online offering and improving it) or if the use of cookies is necessary to fulfill our contractual obligations.

Withdrawal and objection (opt-out): Regardless of whether the processing is based on consent or legal permission, you have the option at any time to withdraw your consent or to object to the processing of your data through cookie technologies (collectively referred to as “opt-out”).

You can first declare your objection using your browser settings, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online offering).

An objection to the use of cookies for online marketing purposes can be made using a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info be explained.

Processing cookie data based on consent: Before we process or have data processed as part of the use of cookies, we ask users for consent that can be withdrawn at any time. Before consent has not been given, cookies may be used, which are necessary for the operation of our online offer. They are used on the basis of our interest and users' interest in the expected functionality of our online offering.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: users (e.g. website visitors, users of online services).
Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. f. GDPR).

You can edit your cookie preferences again here: [cc-edit]

6. Google Analytics
We use Google Analytics, a web analysis service provided by Google Inc. (“Google”) one. Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on activities within this online offer and to provide us with other services related to the use of this online offer and Internet usage. Pseudonymous user profiles of users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of users is abbreviated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there.

The IP address transmitted by the user's browser is not combined with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and related to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information on Google's use of data for advertising purposes, settings and objection options, please visit Google's websites: https://www.google.com/intl/de/policies/privacy/partners (“Use of data by Google when you use our partners' websites or apps”), http://www.google.com/policies/technologies/ads (“use of data for advertising purposes”), http://www.google.de/settings/ads (“manage information that Google uses to show you advertising”) and http://www.google.com/ads/preferences (“Determine which ads Google shows you”).

The data collected by this service is transferred to a third country (USA). In accordance with Article 49 (1) lit a in conjunction with Article 6 (1) (a) GDPR, your express consent is the legal basis for this data transfer. Even before you gave your consent, we have informed you that the USA does not currently have a level of data protection that meets EU standards. For this reason, the European Court of Justice has declared the “Privacy Shield” (adequacy decision in accordance with Article 45 GDPR) invalid in the Schrems II case.

7. Google Re/Marketing Services
We use the marketing and remarketing services (“Google Marketing Services” for short) from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

Google marketing services allow us to display ads for and on our website in a more targeted manner in order to only present users with ads that potentially match their interests. For example, if users are shown ads for products they were interested in on other websites, this is referred to as “remarketing.” For these purposes, when you access our and other websites on which Google marketing services are active, Google directly executes a code from Google and integrates so-called (re) marketing tags (invisible graphics or code, also known as “web beacons”) into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content they are interested 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 further information on the use of the online offer. The IP address of users is also collected, and as part of Google Analytics, we report that the IP address is abbreviated within member states of the European Union or in other states party to the Agreement on the European Economic Area and only in exceptional cases transmitted in its entirety to a Google server in the USA and abbreviated there. The IP address is not combined with user data within other Google offers. The above information may also be combined with such information from other sources. If the user then visits other websites, ads tailored to him can be shown according to his interests.

User data is processed pseudonymously as part of Google marketing services. This means that Google does not store and process the user's name or email address, for example, but processes the relevant data based on cookies within pseudonymous user profiles. In other words, from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by “DoubleClick” about users is transmitted to Google and stored on Google's servers in the USA.

The Google marketing services we use include the “Google AdWords” online advertising program. In the case of Google AdWords, every AdWords customer receives a different “conversion cookie.” Cookies can therefore not be traced via the websites of AdWords customers. The information collected using the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that personally identifies users.

We include third-party advertisements based on the Google marketing service “DoubleClick”. DoubleClick uses cookies to enable Google and its partner websites to display ads based on users' visits to this website or other websites on the Internet.

We also include third-party advertisements based on the Google marketing service “AdSense”. AdSense uses cookies, which enable Google and its partner websites to display ads based on users' visits to this website or other websites on the Internet.

Another Google marketing service we use is the “Google Tag Manager”, which can be used to integrate other Google analysis and marketing services into our website (e.g. “AdWords”, “DoubleClick” or “Google Analytics”).

For more information about Google's use of data for marketing purposes, please visit the overview page: https://www.google.com/policies/technologies/ads, Google's privacy policy is available at https://www.google.com/policies/privacy retrievable.

If you would like to object to collection by Google marketing services, you can use the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.

8. Facebook social plug-ins
Our online offering uses social plugins (“plugins”) from 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 can be identified by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

When a user accesses a function of this online offer that contains such a plugin, their device creates a direct connection to the Facebook servers. The content of the plugin is transmitted directly from Facebook to the user's device and integrated by the user into the online offering. User profiles of users can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects using this plugin and therefore informs users to the best of our knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed 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 pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible that Facebook will find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

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

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his membership data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Further settings and 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 site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

9. Facebook remarketing
Our online offering uses so-called “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 based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). With the help of the Facebook pixel, Facebook is able to identify visitors to our offer as a target group for displaying ads, so-called “Facebook ads.” Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to Facebook users who have also shown an interest in our website. This means that with the help of the Facebook pixel, we want to ensure that our Facebook ads match the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also understand 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 you visit our websites and can save a so-called cookie, i.e. a small file, on your device. If you then log in to Facebook or visit Facebook while logged in, your visit to our website will be noted in your profile. The data collected about you is anonymous to us and therefore does not provide us with any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible. The processing of data by Facebook is carried out within the framework of Facebook's data usage policy. Accordingly, you will find further information on how the remarketing pixel works and how Facebook ads are displayed in general, in Facebook's data usage policy: https://www.facebook.com/policy.php.

You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To do this, you can visit the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads or the objection via the US side http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ explain. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

10. Twitter buttons
We use the Twitter service buttons. These buttons are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. They can be identified by terms such as “Twitter” or “Follow” or associated with a stylized blue bird. With the help of the buttons, it is possible to share a post or website of this online offer on Twitter or to follow the provider on Twitter.

When a user accesses a website on this online offer that contains such a button, their browser creates a direct connection to Twitter's servers. The content of the Twitter button is transmitted from Twitter directly to the user's browser. We therefore have no influence on the amount of data that Twitter collects with the help of this plugin and inform users to the best of our knowledge. According to this, only the user's IP address and the URL of the respective website are transmitted when the button is accessed, but not used for purposes other than displaying the button.
Further information can be found in Twitter's privacy policy at http://twitter.com/privacy.

11. Newsletter
With the following information, we will inform you about the content of our newsletter as well as the registration, shipping and statistical evaluation procedures as well as your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We send newsletters, emails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or legal permission. If the content of the newsletter is specifically described as part of a subscription to the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain the following information: “Events, our products, product offers, promotions and general information about our company”.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign email addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes saving the time of registration and confirmation, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Shipping service provider: The newsletter is sent by “iubenda s.r.l — Via Torino, 2 — 20123 Milan (Italy)” (hereinafter referred to as “shipping service provider”). The privacy policies of our shipping service providers can be found on the website at https://www.thenewsletterplugin.com

The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on the servers of the shipping service provider. The shipping service provider uses this information to send and evaluate the newsletters on our behalf. In addition, according to its own information, the shipping service provider may use this data to optimize or improve its own services, e.g. to technically optimize delivery and the presentation of newsletters or for economic purposes to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or pass them on to third parties.

Registration data: To sign up for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide the following data: “First and last name and address to personalize the newsletter. Date of birth and gender to adapt the content of the newsletter to the interests of our readers.”

Statistical collection and analyses — The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from the mailing service provider's server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, are first collected. This information is used to technically improve the services based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor that of the shipping service provider to observe individual users. The evaluations are much more useful for us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

Cancellation/Withdrawal — You can unsubscribe from our newsletter at any time, i.e. withdraw your consent. At the same time, your consent to its dispatch by the shipping service provider and the statistical analyses expire. A separate cancellation of the shipment by the shipping service provider or the statistical evaluation is unfortunately not possible. A link to cancel the newsletter can be found at the end of each newsletter.

12. Integration of third-party services and content
It may happen that content or services from third-party providers, such as city maps or fonts from other websites, are integrated into our online offering. The integration of content from third-party providers always requires that the third-party providers recognize the users' IP addresses, as they would not be able to send the content to the user's browser without the IP address. The IP address is therefore required to display this content. In addition, providers of third-party content can set their own cookies and process user data for their own purposes. User profiles of users can be created from the processed data. We will use this content as sparingly and avoid data as much as possible and choose reliable third-party providers with regard to data security.

The following presentation provides an overview of third-party providers and their content, as well as links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):

External fonts from Google, Inc., https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated through a server call to Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
Maps provided by the “Google Maps” service provided by the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
Videos from the “YouTube” platform from third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.

13. Integration of online forms
Online forms are provided by our service provider DWFormmailer (https://www.dw-formmailer.de). For the purpose of transmission and processing, the data is forwarded to DWFormmailer's servers.
The operator of this Internet portal is Wolfgang Dürr (sole proprietorship), In den Kehlen 4, 97342 Marktsteft, Germany. There is an agreement with the service provider for order data processing.

14. Web fonts
Google Fonts
With our contract processor Google Fonts, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, we process connection data and browser data for the purpose of providing the fonts required by the web browser to display the website. This data is only processed for the time required to select and transmit the fonts. The legal basis for data processing is legitimate interest (absolute technical necessity to provide and deliver the “website” service you have expressly requested through your call) in accordance with Article 6 (1) (f) GDPR.
Insofar as Google Fonts independently processes the data, Google is the sole responsible party for this. Details can be found in the Google Fonts privacy policy and FAQ.

Font Awesome
With our contract processor Fontawesome, Fonticons, Inc., 6 Porter Road, Apartment 3R, Cambridge, MA 02140, USA, we process connection data and browser data for the purpose of providing the fonts required by the web browser to display the website. This data is only processed for the time required to select and transmit the fonts.
The legal basis for data processing is legitimate interest (absolute technical necessity to provide and deliver the “website” service you have expressly requested through your call) in accordance with Article 6 (1) (f) GDPR.
Insofar as Fontawesome carries out further independent processing of the data, Fontawesome is the sole responsible party for this. Details can be found in Fontawesome's privacy policy.

15. Users' rights and deletion of data
Users have the right, upon request, to receive free information about the personal data that we have stored about them.
In addition, users have the right to correct incorrect data, withdraw consent, block and delete their personal data, and the right to lodge a complaint with the competent supervisory authority if unlawful data processing is assumed.

The data stored by us will be deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any legal storage requirements.

16. Changes to the privacy policy
We reserve the right to change the privacy policy in order to adapt it to changing legal situations or to changes in the service and data processing. However, this only applies with regard to explanations of data processing. If user consent is required or parts of the data protection declaration contain provisions relating to the contractual relationship with the users, the changes will only be made with the consent of the users.
Users are asked to regularly inform themselves about the content of the privacy policy.

As of June 2, 2021

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