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Privacy policy

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section “Information on the controller” in this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter into a contact form.

Other data is collected automatically or after you have given your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given your consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

Analysis tools and third-party tools

When you visit this website, your surfing behaviour may be statistically analysed.

This is done primarily with so-called analysis programs.

You can find detailed information on these analysis programs in the following privacy policy.

2. Hosting

We host the content of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access data and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

Our host(s) will only process your data to the extent necessary to fulfil its/their performance obligations and will follow our instructions with regard to this data.

We use the following host(s):

maxcluster GmbH
Lise-Meitner-Str. 1b
D-33104 Paderborn

Data processing on behalf

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the processor processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy. 

When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done. 

We would like to point out that data transmission over the internet (e.g. when communicating by e-mail) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the controller

The controller responsible for data processing on this website is:

Novogenia Marketing GmbH
Strass 19 5301
Eugendorf / Austria

Phone: +43 662 42 50 99 11
E-mail: service@novogenia.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage period

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure will take place once these reasons no longer apply.

General information on the legal basis for data processing on this website 

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, where special categories of data are processed in accordance with Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your terminal device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TTDSG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if it is required to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Note on data transfers to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you, as the data subject, being able to take legal action against this. It therefore cannot be ruled out that US authorities (e.g. intelligence services) may process, analyse and permanently store your data located on US servers for surveillance purposes. We have no influence over these processing activities.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR). 

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, erasure and rectification

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us about this at any time. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data. 
  • If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure. 
  • If we no longer need your personal data but you need it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure. 
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data. 

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. 

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to advertising e-mails

We hereby object to the use of contact data published in connection with the legal notice obligation for sending advertising and information material that has not been expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data collection on this website

Cookies

Our websites use so-called “cookies”. Cookies are small data packets and do not cause any damage to your terminal device. They are stored on your terminal device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or they are automatically deleted by your web browser. 

In some cases, cookies from third-party companies may also be stored on your terminal device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services). 

Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to analyse user behaviour or to display advertising. 

Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping cart function) or to optimise the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TTDSG); consent can be withdrawn at any time. 

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited. 

Insofar as cookies from third-party companies or for analysis purposes are used, we will inform you about this separately within this privacy policy and, if necessary, request your consent.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not combined with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be recorded.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to erase it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiries by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be withdrawn at any time.

The data you send to us via contact requests will remain with us until you ask us to erase it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. It is used solely to manage and deliver the tools integrated via it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google's parent company in the United States.

Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on its website. Where consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and agree to receive the newsletter. Further data is not collected or is collected only on a voluntary basis. To handle the newsletter, we use newsletter service providers, which are described below.

By agreeing to receive the newsletter, you also consent, within the meaning of Section 174 of the Telecommunications Act (Telekommunikationsgesetz), to receiving advertising e-mails about our products, services, activities, promotions and other relevant initiatives; in addition, we are entitled to send you reminder e-mails if the purchase process has not been completed; this consent can be withdrawn at any time.

ActiveCampaign

This website uses ActiveCampaign to send newsletters. The provider is ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA. 

ActiveCampaign is a service that can be used, among other things, to organise and analyse the sending of newsletters. The data you enter for the purpose of receiving the newsletter is stored on ActiveCampaign's servers in the USA.

Data analysis by ActiveCampaign

ActiveCampaign enables us to analyse our newsletter campaigns. For example, we can see whether a newsletter message has been opened and, if applicable, which links have been clicked. In this way, we can determine, among other things, which links were clicked particularly often.

We can also see whether certain predefined actions were carried out after opening / clicking (conversion rate). For example, we can see whether you made a purchase after clicking on the newsletter.

ActiveCampaign also enables us to divide newsletter recipients into different categories (“clustering”). Newsletter recipients can be subdivided, for example, by age, gender or place of residence. In this way, the newsletters can be better adapted to the respective target groups. If you do not want any analysis by ActiveCampaign, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

You can find detailed information on the functions of ActiveCampaign at the following link: https://www.activecampaign.com/email-marketing.

You can find ActiveCampaign's privacy policy at: https://www.activecampaign.com/privacy-policy.

Legal basis

Data processing is based on your consent (Art. 6(1)(a) GDPR). You can withdraw this consent at any time. The lawfulness of data processing operations already carried out remains unaffected by the withdrawal.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.activecampaign.com/legal/scc and https://www.activecampaign.com/de/legal/gdpr-updates/privacy-shield.

Storage period

The data you provide to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored by us for other purposes remains unaffected.

After you have been removed from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if this is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and is not combined with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

Data processing on behalf

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the processor processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

7. eCommerce and payment providers

Processing of customer and contract data

We collect, process and use personal customer and contract data to establish, define the content of and amend our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The customer data collected will be erased after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.

Supplement to the privacy policy

Use of Claude Cowork (Anthropic)

We use the AI platform Claude Cowork to support internal work processes and the handling of information.

In the course of its use, authorised employees may process content that contains personal data. This may include, for example, analysing documents, creating drafts, summarising information or assisting with administrative tasks.

It is used exclusively in compliance with our internal data protection and security policies and the technical and organisational measures (TOMs).

Legal basis

Processing is carried out on the following legal bases:

  • Art. 6(1)(a) GDPR (consent)
  • Art. 6(1)(b) GDPR (performance of a contract)
  • Art. 6(1)(f) GDPR (legitimate interest in efficient business processes)
  • and, where applicable, Art. 6(1)(c) GDPR (legal obligations)

Data processing by Anthropic

When Claude Cowork is used, Anthropic processes personal data as a processor on behalf of the respective business customer. According to Anthropic, control over the processed data generally remains with the customer company. Data from Claude Cowork environments is not used by default to train generative AI models unless a separate agreement has been made.

Categories of data concerned

Depending on the use case, the following data in particular may be processed:

  • Names and contact details
  • Communication content
  • Documents and file attachments
  • Contract and project data
  • other information or data provided by the user

Transfer to third countries

Processing may take place on servers outside the European Union or the European Economic Area. In such cases, we ensure that appropriate safeguards pursuant to Art. 44 et seq. GDPR are in place, for example by concluding EU standard contractual clauses or other legally recognised protection mechanisms.

Confidential information

Employees are instructed and obliged to process particularly sensitive data as well as personal data or trade secrets in Claude Cowork only if this is necessary for the respective purpose, internal policies permit it and this data has been anonymised or pseudonymised before use.