I. APPLICABILITY OF THIS PRIVACY POLICY
II. INFORMATION WE COLLECT AND RECEIVE
III. HOW WE USE INFORMATION
IV. LEGAL BASIS
V. DATA RETENTION
VI. RECIPIENTS OF THE DATA
VII. COOKIESVIII. SECURITY
IX. AGE LIMITATIONS
X. EFFECTIVE DATE AND CHANGES TO THIS PRIVACY POLICY
XI. INTERNATIONAL DATA TRANSFERS
XII. DATA PROTECTION OFFICER
XIII. IDENTIFYING THE DATA CONTROLLER AND PROCESSOR
XIV. YOUR RIGHTS
XV. DATA PROTECTION AUTHORITY
XVI. CONTACT INFORMATION
The column on the right provides a short explanation of the terms of use and is not legally binding.
I. APPLICABILITY OF THIS PRIVACY POLICY
§ 1.1 Scope. This “Privacy Policy” applies to the services (the "Romulus Services") provided on www.hansmengroup.com and other websites owned by us (the "Romulus Websites"), as well as other interactions (e.g., customer service requests, user conferences, etc.) you may have with us. Romulus Services specifically include your visit of the Romulus Websites.
§ 1.2 Consent. If you do not agree to the terms of our Privacy Policy, do not access or use the Romulus Services, the Romulus Websites, or any other aspect of our business.
§ 1.3 Third Party Providers. This Privacy Policy does not apply to any third party applications or software that are integrated with the Romulus Services through the Romulus Websites (“Third Party Services”), or any other products, services or businesses of any other third party.
§ 1.4 Definitions. "We", "our" and "us" refer to the persons listed in Art. XVI.
Basically,
whenever you browse our Romulus Websites, or use our Romulus Services, please observe this Privacy Policy.
II. INFORMATION WE COLLECT AND RECEIVE
§ 2.1 Other Information. We collect, generate and/or receive other information and data ("Other Information"):
(a) Usage Information.
i. Romulus Services Metadata. When you use the Romulus Services, metadata is generated that provides additional context about the way you use the Romulus Services. For example, we may log features, content, links or Third Party Services (as defined below) that you have viewed or used.
ii. Log Data. Like most websites, our servers also automatically collect information when you access the Romulus Websites and record it in log files. This log data includes the Internet Protocol (IP) address, the address of the website visited prior to your use of the Romulus Websites, browser type and settings, the date and time you used the Romulus Websites, browser configuration and plug-in information, language settings, and cookie data.
iii. Device Information. We may also collect information about devices used to access the Romulus Services, including information on the type of device, the operating system, device settings, application IDs, unique device identifiers, and crash data.
iv. Location Information. We may receive information from you and other third parties that helps us approximate your location, such as an IP address received from your browser or your device. We may also collect location information from devices in accordance with the settings of your device.
(b) Third Party Data. We may receive data about your visits to the Romulus Websites, marketing campaigns and other matters related to our business from affiliates, our partners, or others that we use to improve our offers or make content provided to you more useful. This data may be combined with Other Information we collect and might include aggregate-level data such as the language and the country you access the Romulus Services from. Or it might be more specific: for example, how well an online marketing or email campaign performed.
(c) Additional Information Provided to Us. We also receive Other Information when submitted to the Romulus Websites or in other ways, such as if you participate in an event, apply for a job, request support, interact with our social media accounts or otherwise communicate with us.
§ 2.2 Automatic Collection. Generally, no one is required by law or contract to provide registration data or other information (collectively, the "Information"). However, certain Information is collected automatically and, if certain information is not provided, we may be unable to provide the Romulus Services.
Basically,
there’s information we collect and receive from you as you browse the Romulus Websites and use the Romulus Services. Please read on regarding our obligations in connection with such information.
III. HOW WE USE INFORMATION
§ 3.1 Other Information. We use Other Information to protect our legitimate interests in operating the Romulus Services, Romulus Websites and our business. Specifically, we use Other Information to
(a) provide, update, maintain and protect the Romulus Services and Romulus Websites;
(b) as required by applicable law, legal process or regulation;
(c) to communicate with you by responding to your requests. If you contact us, we may use your Other Information to respond;
(d) to send emails and other communications. We may send you service, technical and other administrative emails and other types of messages, e.g. push-notifications. We may also contact you to inform you about changes in our Romulus Services, our Romulus Services’ offerings, and important Romulus Services-related notices, such as security and fraud notices. These communications are considered part of the Romulus Services and you may not opt out of them. In addition, we sometimes send emails or other messages about new product features, promotional communications or other news about our business. These are marketing messages, so you can control whether you receive them. If you have additional questions about a message you have received from us, please contact us;
(e) to investigate and help prevent security issues and abuse.
§ 3.2 Personal Data and Anonymized Data. If Information is aggregated or de-identified, so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”.
Basically,
we only use the data we hold to provide and improve the Romulus Services, and for related business purposes. Of course, we always comply with all applicable laws.
IV. LEGAL BASIS
§ 4.1 We process your data in accordance with the provisions of
(a) the General Data Protection Regulation (GDPR);
(b) Austrian data protection laws, such as the Data Protection Act (Datenschutzgesetz, DSG); and/or
(c) other countries, if applicable. These may be laws of the state you reside in.
V. DATA RETENTION
§ 5.1 We may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy.
VI. RECIPIENTS OF THE DATA
§ 6.1 Policies and Practices. This section describes how we may share and disclose Information. In general you determine your own policies and practices for the sharing and disclosure of Information, and we do not control how they or any other third parties choose to share or disclose Information.
§ 6.2 Applicable Law. We will solely share and disclose Registration Data in accordance with applicable law and legal process.
§ 6.3 Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers. Prior to engaging any third party Subprocessor, we perform diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement implementing its applicable obligations.
(a) Tools and applications linked to our Platform & Services.
i. We use the following services of Google Inc., a company headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as described below.
- Google Analytics: Google Analytics is a web analysis service. This service uses so-called "Cookies" (as described in Art. VII). These Cookies generate information and such information is usually transmitted to a server in the USA. Google will, on our behalf, use this information to evaluate your usage of the Romulus Websites, to compile reports on website activities, and to provide us with additional services associated with website and internet usage. However, Google Analytics may also use data for its own purposes, existing independently of the services provided to us.
We have extended Google Analytics on the Romulus Websites with the code "gat._anonymizeIp();" to ensure anonymized collection of IP addresses. The IP address that your browser sends as part of the Google Analytics service will not be merged by Google with other data..
You can prevent the collection, transmission and processing of data generated by cookies and related to your use of the Romulus Websites, including your IP address, by Google Analytics by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. You can also prevent the storage of cookies required by Google Analytics by configurating the settings in your browser.
(b) More Information. Should you require any further information on the type, scope, purposes and possibility to opt-out of the services described in § 6.3(a), we recommend that you read the companies’ respective data protection policies.
(c) Links. We also include links to other websites on the Romulus-Websites. These are for informational purposes only. We have no control over these websites and their content, which means that they are not covered by the provisions of this Privacy Policy. If you click on a link, the operator of the website may collect data on you and process this in accordance with their own data protection policy, which may deviate from ours.
(d) Tools and applications that go beyond the platform.
In addition, you may have the option of interacting with certain social networks on the Romulus Websites via plugins. Clicking on a plugin for one of these social networks will activate it and the plugin will establish a connection to the server of the respective network. We have no influence on the scope or the content of the data that is transmitted to the operator of the respective social network when you click on the plugin.
§ 6.4 Corporate Affiliates. We may share Other Information with our corporate affiliates.
§ 6.5 Changes to our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
§ 6.6 Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share such data with prospects or partners for business or research purposes.
§ 6.7 Complying with Laws. If we receive a request for information, we may disclose Other Information, if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
§ 6.8 Enforcing our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of ourselves or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
§ 6.9 Consent. We may share Other Information with third parties when we have consent to do so.
Basically,
we don’t sell your data or share it otherwise with third parties, unless it helps provide the Romulus Services or we are legally required to do so.
VII. COOKIES
§ 7.1 Definition. “Cookies” are small text files that are sent to your computer or mobile device by us to enable the functionality of the Romulus Services or to facilitate their use.
§ 7.2 Types of Cookies. Cookies can be divided into different categories, depending on their characteristics, as shown in the following.
(a) Storage Duration.
i. Temporary Cookies only exist as long as your browser is open and are automatically deleted when you close your browser. They exist only for the particular period of use of the Romulus Services, i.e., a "session".
ii. Permanent Cookies will exist until deleted by you or your browser or their expiration.
(b) Creator of the Cookies.
i. First-party Cookies are set by us.
ii. Third-party Cookies are set by third parties.
(c) Necessity.
i. Necessary Cookies are technically required for the operation of the Romulus Websites and Romulus Services.
ii. Non-necessary Cookies are used to improve and facilitate your use of the Romulus Services but are not technically essential. These include, for example, Cookies that are used to create personalized advertising for you.
§ 7.3 Our Cookies. We use the following cookies:
(a) Necessary Cookies;
(b) Analytics Cookies; and
(c) Advertising and social media Cookies.
§ 7.4 A detailed list of the cookies we use is attached to this Privacy Policy as Schedule § 7.4 of this Privacy Policy.
§ 7.5 Refusing Cookies. You may reject all Cookies, except for necessary Cookies,
(a) when visiting the Romulus Website, via the Cookie banner; or
(b) in your browser settings. How this works, depends on the browser you are using. A link to the instructions for the most common browsers can be found here:
i. Microsoft Edge: https://support.microsoft.com/de-de/windows/l%C3%B6schen-und-verwalten-von-cookies-168dab11-0753-043d-7c16-ede5947fc64d.
ii. Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies.
iii. Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647.
iv. Safari: http://support.apple.com/kb/PH5042.
v. Opera: http://www.opera.com/browser/tutorials/security/privacy/.
VIII. SECURITY
§ 8.1 Security. We take security of your data very seriously. We work hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, we cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.
Basically,
we constantly try to improve the security of our system to protect your data. It is a top concern for us.
IX. AGE LIMITATIONS
§ 9.1 Minimum Age. We allow only persons who are
(a) at least 18 years old; or
(b) younger than 18 years old and have consent of their legal guardian,
to use the Romulus Services.
Basically,
if you are below 18, you must not use the Romulus Services without you legal guardian’s consent.
X. EFFECTIVE DATE AND CHANGES TO THIS PRIVACY POLICY
§ 10.1 Effective Date. This Privacy Policy becomes effective on 15.08.2022.
§ 10.2 Changes. We may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should not use the Romulus Services.
Basically,
please check regularly as this Privacy Policy might change over time.
XI. INTERNATIONAL DATA TRANSFERS
§ 11.2 The processing pursuant to § 11.1 is based on a data processing contract that contains the standard contractual clauses, published by the Commission of the European Union.
Basically,
we have contracts in place to make sure that all your data is safe, even if it is processed outside the EEA.
XII. DATA PROTECTION OFFICER
§ 12.1 To communicate with our Data Protection Officer, please email info@hansmengroup.com.
Basically,
this is the person you can approach for any concerns regarding data protection.
XIII. IDENTIFYING THE DATA CONTROLLER AND PROCESSOR
§ 13.1 Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, we are the controller of Other Information.
Basically,
we acknowledge our responsibilities in handling you data and our crucial role in keeping it secure and safe.
XIV. YOUR RIGHTS
§ 14.1 Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. We will strive to let you do this using the settings and tools provided in your Romulus Services account. If you cannot use the settings and tools, contact us for additional access and assistance.
§ 14.2 To the extent that our processing of your Personal Data is subject to the General Data Protection Regulation, or applicable laws covering the processing of Personal Data in the United Kingdom, we rely on our legitimate interests, described above, to process your data. We may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to our use of your Personal Data for this purpose at any time.
Basically,
you have the right to know which personal data we hold regarding you as an individual.
XV. DATA PROTECTION AUTHORITY
§ 15.1 Data Protection Authority. Subject to applicable law, you also have the right to
(a) restrict our use of Other Information that constitutes your Personal Data; and
(b) lodge a complaint with your local data protection authority or the Austrian Data Protection Authority, which is our lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:
Austrian Data Protection Authority
Barichgasse 40-42,
1030 Vienna
Austria / Europe
Telephone: +43 1 52 152-0
E-Mail: dsb@dsb.gv.at
§ 15.2 United Kingdom. If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.
Basically,
our handling of data protection matters is supervised by government authorities that you can turn to, if you have question or concerns.
XVI. CONTACT INFORMATION
§ 16.1 Please also feel free to contact us if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at info@hansmengroup.com or at our mailing address below:
Romulus Consulting GmbH, Cumberlandstraße 29/17, 1140 Wien, Austria.
