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As of August 1, 2019

This Privacy Policy applies to all of the services offered on sites owned and operated by us (the “Services”). When we refer to ‘’we’’ or ‘’our’’, we are referring to KaProblem e.U., Stefan Nothegger, Weissachstraße 6e, A-6330 Kufstein, Austria . We are the controller in accordance with the General Data Protection Regulation (GDPR).

1. Fundamental Principles of Privacy Policy

In the operation of our business, we may collect Personal Information about you, and we recognize and respect the privacy rights with regard to, and the importance of protecting, such information. To show our deepest commitment and responsibility to safeguard your Personal Information, we have established this Privacy Policy.

Our management and employees are expected to strictly observe all regulatory, legal and corporate requirements for handling and protecting Personal Information. We have also established internal safety standards, accountability protocols and procedures, and preventive measures to protect against unauthorized access, disclosure, alteration or destruction of Personal Information.

As part of our continuous efforts to monitor and ensure the safety of your Personal Information, we regularly review our personal information management system, including compliance by our management and employees with this Privacy Policy.

2. Proper Acquisition

We acquire Personal Information only by proper and lawful means and not through deception or any other wrongful means. When Personal Information is provided to us by third parties, we take appropriate steps to verify that such information is reliable and obtained in a proper manner.

3. Processing of Personal Data/Purpose of Processing

  1. When browsing our website for informational purposes

    The provider of the Websites automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:

    1. Browser type and browser version
    2. Operating system used
    3. Referrer URL
    4. Host name of the accessing computer
    5. Time of the server request
    6. IP address
    These data will not be combined with data from other sources.

    The basis for data processing is Art. 6 (1) (f) DSGVO, which allows the processing of data on prevailing legitimate interest of the controller. Our legitimate interest is to ensure unimpeded and trouble-free access to our Websites.

    For further information on the processing by cookies and tools of third party providers see Section 4 below.

    The hosting of the Websites and our services offered is carried out by an external service provider on our behalf. Your data will be stored on protected servers within the EU. Access is only possible to a few specially authorised persons who are involved with the technical, commercial or editorial support of the servers.

  2. When registering for a user account

    When registering for a user account we collect your username, e-mail, gender, first name, surname, birthdate, zip code, city and country and password.

    When you register via your social media account (Facebook, Google+, Yahoo or OpenID) the concerned social media provider will automatically provide to us your personal account data such as your name, social media account ID, email, workplace, gender or further account-related data or profile pictures. Please note that not all of the provided data is stored to our data bases (e.g. no information regarding workplace or profile pictures). However, in such case you are using a third party service which is independent of us and whose data processing procedures we are unable to influence. Please find further information on data protection at the websites of the relevant third party service providers.

    The processing of your personal data is necessary to fulfil our contractual obligation towards you (Art. 6 (1) (b) GDPR). The processing is further covered by our legitimate interest in offering the services and enhancing user experience and convenience with our services (Art. 6 (1) (f) GDPR).

    Your data will be stored, until you delete your account.

  3. When using our contact form

    When you use our contact form we collect your e-mail address as well as the content you provide.

    We will only process your personal data in order to process your request and provide you with the respective feedback.

    The personal data is processed I order to protect our legitimate interest to offer you the service and enhance customer satisfaction (Art. 6 (1) (f) GDPR).

    We will delete your personal data once your request has been answered finally.

  4. When subscribing to our newsletter service

    If you have given your consent, we will send you a newsletter/information at irregular intervals to inform you about news on our Services as well as on the Services of our affiliated companies.

    For this we need your e-mail address. You can unsubscribe from the newsletter at any time by clicking on the corresponding link at the end of the e-mail. You can also revoke this consent at any time with effect for the future by e-mail to [email protected] .

    The legal basis for sending the newsletter is Art. 6 (1) (a) GDPR.

    If you withdraw your consent or rightfully object to the processing, we will delete your personal data immediately.

4. Cookies and other Technologies
  1. We use cookies with our services. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you use our services. Cookies do no damage to your end device and do not contain viruses, Trojans or other malware. Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that we immediately become aware of your identity. The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our Website. These will be deleted automatically after leaving our site. In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our Website and to evaluate it for you for the purpose of optimising our offer. These cookies enable us to automatically recognize when you return to our site that you have already been with us. These cookies are automatically deleted after a defined period of time. The data processed by cookies is required for the above purposes in order to protect our legitimate interests and those of third parties (Art. 6 (1) (f) GDPR). Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our Website.
  2. For the purpose of demand-oriented design and continuous optimization of our Website, we use Google Analytics, a web analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymized user profiles are created and cookies (see above) are used. The information generated by the cookie about your use of this Website such as
    1. browser type/version,
    2. operating system used,
    3. referrer URL (the previously visited page),
    4. host name of the accessing computer (IP address),
    5. time of the server request,
    are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the Website, to compile reports on the Website activities and to provide further services associated with the use of the Website and the Internet for the purposes of market research and demand-oriented design of these Internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company. Under no circumstances will your IP address be merged with other data from Google. The IP addresses are anonymized so that an assignment is not possible. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website. You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on ( ). As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on this link. An opt-out cookie is set to prevent future collection of your data when you visit this Website. The opt-out cookie is only valid in this browser and only for our Website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help ( ).
  3. We measure the reach of our website with Matomo, an open source tool that we operate on our own server. A cookie may be set on the user's end device, via which the activities can be tracked and, for example, recurring visits can be recognized. The user's IP address is automatically shortened, so it is no longer possible to draw conclusions about individual persons. Among other things, the approximate geographic location, end device, screen resolution, browser and pages visited including the length of stay are evaluated. Insofar as we obtain the user's consent, the processing of data takes place on the legal basis of Article 6 Paragraph 1 Subparagraph 1 Letter a) GDPR. Otherwise, it is based on Article 6 Paragraph 1 Subparagraph 1 Letter f) GDPR. Our legitimate interest lies in optimizing our website, improving our offers and online marketing.
  4. We use DoubleClick, a remarketing service from Google. The service enables users who have already visited our Internet pages and online services and are interested in the offer to be addressed again through targeted advertising on the pages of the Google Partner Network. The insertion of the advertisement takes place via the use of cookies. Cookies can be used to analyse user behaviour when visiting the website and can then be used for targeted product recommendations and interest-based advertising. If you do not wish to receive interest-based advertising, you can disable Google's use of cookies for these purposes by visiting . Alternatively, you can disable the use of cookies by third parties by visiting the opt-out page of the Network Advertising Initiative: . Information about your use of this website is usually transferred to a Google server in the USA and stored there.
  5. This website uses Google Tag Manager. Google Tag Manager is a solution operated by Google that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.

5. Cross-Border Data Transfers

As indicated in this Privacy Policy, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards than your country of residence. Please note, that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to keep up an adequate level of data protection also when sharing your personal data with such countries. We transfer your personal data to Japan. This transfer is either necessary for the fulfilment our contractual obligations as service provider, subject to your consent or covered by EU Standard Contractual Clauses.

6. Transfer of Personal Information to Third Parties

Except as permitted by applicable data protection laws, we will not, without your prior consent, provide or disclose your Personal Information to third parties except in the following circumstances:

  1. To comply with any applicable law, regulation, or governmental request;
  2. To protect against immediate harm to personal safety or property, and procuring prior consent from the individual concerned is difficult;
  3. For public health reasons, protection of children’s privacy and other public interest concerns, and procuring prior consent from the individual concerned is difficult;
  4. To provide necessary cooperation to relevant national and local governmental authorities, and procuring prior consent from the individual concerned hampers or jeopardizes such cooperation efforts;
  5. For outsourcing to third party service providers in connection with the performance of certain services on our behalf, such as direct mailing and phone calls, through contractual and written agreements requiring adherence by such third parties to confidentiality and privacy terms;
  6. For outsourcing to processors of payment transactions and provider of related services in connection with your payment transactions, through contractual and written agreements requiring adherence by such third parties to confidentiality and privacy terms.

7. Third Party Service Provider

When we share or disclose your Personal Information with third party service providers for processing or handling Personal Information for us, we conduct thorough investigation to verify the reliability and trustworthiness of such service providers, and take necessary measures to ensure their compliance with applicable laws, our Privacy Policy and any other appropriate confidentiality and security measures.


Sending of E-Mails and Newsletters is dome using a platform called „MailGun“, a platform of the US-Company Mailgun Technologies, Inc. 548 Market St. #43099 San Francisco, CA 94104, USA. You can see their privacy policy here: Using this service provider is done according to Art. 6 Abs. 1 lit. f DSGVO and a DPA according tp Art. 28 Abs. 3 S. 1 DSGVO.

8. Security

We have implemented measures, including SSL or TLS encryption, designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

9. No requirement to provide personal data

The provision of your personal data will generally be voluntarily and there is no statutory nor contractual obligation to provide your personal data. We generally do not contractually require provision of your personal data; but note that in any event non-provision of personal data might exclude you from using some of our services or parts thereof.

10. Data Retention

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this Policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements. In case we maintain a user account, your data will be stored for the duration such account remains active. In case of consent, your personal data will be at the latest deleted without undue delay after withdrawal of such consent.

11. Your Rights

You have the right, at any time

  1. without giving reasons according to Art. 15 GDPR to request information about your data stored with us. With the exception of any connection fees charged by your provider, you will not incur any costs as a result of the enquiry;
  2. to have the data corrected in accordance with Art. 16 GDPR;
  3. to have the data deleted in accordance with Art. 17 GDPR;
  4. to have the data blocked in accordance with Art. 18 GDPR;
  5. to object to the processing for sending the newsletter according to Art. 21 (2) GDPR;
  6. to object to other forms of processing of your personal data in accordance with Art. 21 (1) GDPR;
  7. to revoke any consent to the collection and use of data given to us in accordance with Art. 7 (3) GDPR;
  8. to receive your personal data in a machine-readable format and to transmit them to another person responsible in accordance with Art. 20 GDPR;
  9. lodge an appeal with a supervisory authority in accordance with Art. 77 GDPR, without prejudice to any other administrative or judicial remedy.

12. Revision

We may revise this Privacy Policy from time to time as necessary. Upon revision, the latest version of the Privacy Policy will be up-loaded to our website.

13. Contact

If you have any questions that this Privacy Policy could not answer, or if you require further information on a particular point, please do not hesitate to contact us at any time. You can reach us as follows under the above address or by writing an e-mail to our Data Protection Officer to

[email protected] .