Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

As of February 20, 2026

Table of contents

Responsible

David Jaime Cocovi Solberg, PalmChrom e.U.
Brigittagasse 5/2/49
1200 Vienna

Email david@palmchrom.com

Phone: +436601169366

Legal notice: www.palmchrom.com/imprint

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

Categories of data subjects

Purposes of processing

Relevant legal basis

Relevant legal basis under the GDPR: Below you will find an overview of the legal basis under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.

Security measures

In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and responses are made to data threats. Furthermore, we take the protection of personal data into account as early as 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.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked and there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing operations.

If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Storage and deletion of data: The following general periods apply under Austrian law for the storage and archiving of personal data, insofar as this is necessary to fulfill legal obligations or to safeguard legitimate interests:

Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

Business services

We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures that are carried out upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfill our main and secondary contractual obligations. This includes the provision of the agreed services, any updating and information obligations, the processing of warranty and other service disruptions, the handling of revocations, terminations of continuing obligations, rescissions, refunds, and the processing of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.

In particular, we process master data such as name, address and, if applicable, company name, contact details such as email address and telephone number, contract and service data such as contract subject matter, contract term, order or transaction number, usage and service data, payment and billing data, as well as communication content and history. Where necessary, we also process data that is disclosed or transmitted to us in the course of executing an order.

In addition, we process the data to protect our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation obligations, and, where applicable, verification and accountability obligations. Processing is also carried out on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and our contractual partners from misuse, endangerment of data, secrets, and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other vicarious agents, insofar as this is necessary for the execution of the contract or to fulfill legal obligations.

Personal data will only be passed on to third parties if this is necessary for the fulfillment of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests, or for the fulfillment of legal obligations. We will provide separate information about any further processing, in particular for marketing purposes, within the scope of this privacy policy.

We will inform the contractual partners which data is required in each individual case when collecting the data, for example by marking it accordingly in online forms or in personal contact.

The data will be deleted as soon as it is no longer required for the aforementioned purposes and there are no legal retention obligations. Legal retention periods, in particular under commercial and tax law, may require longer storage. We delete data that has been transmitted in the context of a specific order after completion of the order and expiry of any retention periods, provided that there are no further legal or contractual obligations to store the data.

The legal basis for processing is Art. 6 (1) lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 (1) lit. c GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6 (1) lit. f GDPR. Insofar as the processing is based on Art. 6 (1) lit. f GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in safeguarding our entrepreneurial capacity to act.

Further information on processing procedures, processes, and services:

Provision of online services and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

Further information on processing procedures, processes, and services:

Use of cookies

The term "cookies" refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online services and to analyze visitor traffic. We use cookies in accordance with legal requirements. To do so, we obtain the consent of users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of consent and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including through the privacy settings of their browser.

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter referred to as "publication media"). Readers' data is only processed for the purposes of the publication media to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication media in this privacy policy.

Further information on processing procedures, processes, and services:

Contact and inquiry management

When contacting us (e.g., by mail, contact form, email, telephone, or social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to contact requests and any requested measures.

Further information on processing procedures, processes, and services:

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending 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. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Contents:

information about us, new products, blog entries.

Further information on processing procedures, processes, and services:

Advertising communication via email, post, fax, or telephone

We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.

Recipients have the right to revoke their consent at any time or to object to advertising communications at any time free of charge using the above-mentioned contact options.

After revocation or objection, we store the data necessary to prove previous authorization for contact or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

Web analysis, monitoring, and optimization

Web analysis (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite reuse. It also enables us to identify areas that require optimization.

In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Further information on processing procedures, methods, and services:

Online marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used to store information about the user that is relevant for the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used, and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.

The statements in the profiles are usually stored in cookies or using similar methods. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing process provider.

In exceptional cases, it is possible to assign clear data to the profiles, primarily if the users are members of a social network, for example, whose online marketing method we use and the network links the user profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, for example, by giving their consent during registration.

We generally only receive access to summarized information about the success of our advertisements. However, we can use conversion measurements to check which of our online marketing methods have led to a conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Information on revocation and objection:

We refer you to the privacy policies of the respective providers and the options for objection (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-regional: https://optout.aboutads.info.

Further information on processing procedures, methods, and services:

Presence on social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users' computers, in which the usage behavior and interests of users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

Further information on processing procedures, methods, and services:

Plug-ins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. 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 may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, but may also be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Further information on processing procedures, methods, and services:

Changes and updates

We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require action on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.

Definition of terms

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.

 

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