This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profile (hereinafter jointly referred to as “online offer”). With regard to the terminology used, such as “processing” or “responsible person” we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
KultEurasia – Association for cultural dialog in Eurasia
Chairwoman: Daniela Lieberwirth
Types of data processed:
- Inventory data (e.g., names, addresses).
- Contact details (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g. websites visited, interest in content, access times).
- Meta / communication data (e.g., device information, IP addresses)
Categories of affected people
Visitors and users of the online offer (in the following we refer to the persons concerned collectively as “users”).
Purpose of processing
- Provision of the online offer, its functions and content.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach measurement / marketing
“Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”). A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” is any process carried out with or without the aid of automated processes or any such series of processes in connection with personal data. The term is broad and includes practically every handling of data.
“Pseudonymisation” is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects of a natural person, in particular aspects of work performance, the economic situation, health, personal data in order to determine preferences analyze or predict interests, reliability, behavior, whereabouts or relocation of this natural person.
“Responsible” is the natural or legal person, authority, institution or other place that alone or jointly with others decides on the purposes and means of processing personal data.
“Processor” means a natural or legal person, authority, institution or other place that processes personal data on behalf of the responsible person.
Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.
In accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons, we make suitable technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling access to the data as well as input, forwarding, ensuring availability and their separation. In addition, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
Cooperation with processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) in the course of our processing, transmit them to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary in accordance with Art. 6 Para. 1 lit. b GDPR to fulfill the contract), you have consented, a legal obligation provides for this or based on our legitimate interests (e.g. Use of agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it happens to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. The processing takes place e.g. in compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Data Subject Rights
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
According to Art. 16 GDPR you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, in accordance with Art. 18 GDPR, to request a restriction on the processing of the data.
You have the right to request that you receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
You also have gem. Art. 77 GDPR the right to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to withdraw your consent according to Art. 7 para. 3 GDPR with effect for the future.
Right to object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct mail
“Cookies” are small files that are stored on the users’ computers. Various information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status can be saved. Cookies are referred to as “permanent” or “persistent” when they remain stored even after the browser is closed. E.g. the login status can be saved if the user visits again after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention requirements. If the data are not deleted because they are required for other legally permissible purposes, their processing will be restricted. I.e. the data will be blocked and not processed for other purposes. This applies e.g. for data that must be kept for commercial law or tax reasons.
According to legal requirements in Austria, the storage takes place in particular for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts / invoices, accounts, business papers, list of income and expenses, etc.), for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Provision of our statutory and business services
We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 Para. 1 lit. b. GDPR, insofar as we offer them contractual services or as part of an existing business relationship or if we are recipients of benefits ourselves. In addition, we process the data of data subjects in accordance with Art. 6 para. 1 lit. f. GDPR based on our legitimate interests, e.g. when it comes to administrative tasks or public relations.
The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. This basically includes inventory and master data of the persons (e.g., name, address, etc.), as well as the contact details (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, contents communicated and Information, names of contact persons) and, if we offer services or products that are subject to payment, payment data (e.g. bank details, payment history, etc.).
We delete data that is no longer required for our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of business processing, we keep the data for as long as it can be relevant for business transactions and with regard to any warranty or liability obligations. The need to store the data is checked every three years; Otherwise, the statutory retention requirements apply.
Comments and contributions
If users leave comments or other contributions, their IP addresses can be stored for 7 days on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR. This is done for our safety if someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case we can be prosecuted for the comment or contribution ourselves and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests in accordance with. Art. 6 para. 1 lit. f. GDPR to process user information for the purpose of spam detection.
The data given in the context of the comments and contributions will be stored permanently by us until the user objects.
Users can be subsribed to follow-up comments with their consent acc. Art. 6 para. 1 lit. a GDPR. The users receive a confirmation email to check whether they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purpose of proving the consent of the user, we save the time of registration along with the IP address of the user and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. On the basis of our legitimate interests, we can save the unsubscribed email addresses for up to three years before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.
Akismet Anti-Spam Check
Our online offer uses the “Akismet” service offered by Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. The use takes place on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f) GDPR. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be saved beyond this period. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used and the computer system and the time of the entry.
Further information on the collection and use of data by Akismet can be found in Automattic’s data protection information: https://automattic.com/privacy/.
Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transmission of the data by not using our comment system. That would be a shame, but unfortunately we don’t see any other alternatives that work just as effectively.
Retrieval of profile pictures at Gravatar
We use the Gravatar service from Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA, within our online offer and in particular in the blog.
Gravatar is a service to which users can log in and store profile pictures and their email addresses. If users leave posts or comments with the respective e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted in encrypted form to Gravatar in order to check whether a profile has been saved for them. This is the sole purpose of the transmission of the e-mail address and it is not used for other purposes, but deleted afterwards.
Gravatar is used on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f) GDPR, because with the help of Gravatar we offer the post and comment writers the opportunity to personalize their posts with a profile picture.
By displaying the images, Gravatar learns the IP address of the user, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s data protection information: https://automattic.com/privacy/.
If users do not want a user picture linked to their Gravatar email address to appear in the comments, they should use an email address that is not stored with Gravatar to comment. We also point out that it is also possible to use an anonymous e-mail address or no e-mail address at all, if the users do not want their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system.
Retrieval of emojis and smilies
The use of the emojis is based on our legitimate interests, i.e. Interest in an attractive design of our online offer acc. Art. 6 para. 1 lit. f. GDPR.
When contacting us (e.g. via the contact form, email, telephone or via social media), the information provided by the user is used to process the contact request in accordance with. Art. 6 para. 1 lit. b) GDPR. The user information can be stored in a customer relationship management system (“CRM system”) or a comparable request organization.
We delete the inquiries if they are no longer required. We review the requirement every two years; The statutory archiving obligations also apply.
Hosting and e-mailing
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).
Collection of access data and log files
We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider .
For security reasons (e.g. to investigate acts of abuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
Jetpack (WordPress Stats)
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Paragraph 1 lit. f DSGVO) we use the Plugin Jetpack (here the subfunction WordPress Stats) which includes a tool for statistical analysis of visitor access and from Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and that enable the analyse of website use.
The information generated by the cookie about your use of this online offer is stored on a server in the USA. Usage profiles of the users can be created from the processed data, whereby these are only used for analysis and not for advertising purposes. Further information can be found in Automattic’s data protection declarations: https://automattic.com/privacy/ and information on Jetpack cookies: https://jetpack.com/support/cookies/.
Facebook pixels, custom audiences and Facebook conversion
Due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes, the so-called “Facebook pixel” of 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 Harbor, Dublin 2, Ireland (“Facebook”) is used.
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only display the Facebook ads placed by us to Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products based on the visited Websites) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we would also like to ensure that our Facebook ads correspond to the potential interest of the 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 have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).
The processing of the data by Facebook takes place within the framework of Facebook’s data usage guidelines. Accordingly, general information on the presentation of Facebook ads can be found in Facebook’s data usage guidelines: https://www.facebook.com/policy.php. Special information and details about the Facebook pixel and how it works can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of advertisements are shown to you within Facebook, you can call up the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are adopted for all devices such as desktop computers or mobile devices.
Online presence in social media
We maintain an online presence within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of the users if they communicate with us within the social networks and platforms, e.g. write articles on our online presence or send us messages
Integration of services and content from third parties
We use content or service offers from third-party providers within our online offer based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. DSGVO) with the aim to use services such as Embed videos or fonts (hereinafter referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as being linked to such information from other sources.
We embed videos from the platform “YouTube” from the provider Google into our website. YouTube is owned by Google. If you visit one of our pages that is equipped with a YouTube plug-in, a connection to the YouTube servers will be established. In doing so, the YouTube server is informed which specific page of our website you have visited. If you are logged into your YouTube account, YouTube can assign your surfing behavior to your personal profile. You can prevent this by logging out of your account. You can find more information on the collection and use of data by YouTube in the information on data protection there.
We integrate maps from the “Google Maps” service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, the users’ IP addresses and location data, which, however, are not collected without their consent (usually in the context of the settings of their mobile devices). The data can be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Use of Facebook social plugin
On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use social plugins (“plugins”) from the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on a blue tile, the terms “like” or a “thumbs up” sign ) or are marked with the addition “Facebook Social Plugin”. The list and the appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
When a user calls up a function of this online offer that contains such a plug-in, his device establishes a direct connection with the Facebook servers. The content of the plug-in is transmitted from Facebook directly to the user’s device, which integrates it into the online offer. In doing so, user profiles can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore inform users according to our level of 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 into Facebook, Facebook can assign the visit to his/her 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 their device to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymized IP address is saved in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options to protect the privacy of users can be found in Facebook’s data protection information: 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 member data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and contradictions 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 website http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices such as desktop computers or mobile devices.
Functions and contents of the Twitter service, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offer. This includes content such as images, videos or text and buttons with which users can share the content of this online service on Twitter.
If the users are members of the Twitter platform, Twitter can assign the above-mentioned content and functions to the profiles of the users there. Data protection declaration: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
Social Media Sharing Links
On our website we link to the social networks Facebook and Instagram as well as to YouTube. In addition, the content of our website can be shared on the aforementioned social media platforms via social media sharing links.
You can find out more about the use of user data by the individual services under the following links:
Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke