1. General

1.1. We, paxfiles.com Inh. Martin Klutz, (the “Company“), e-mail address: [info[at]paxfiles.com] (the „E-Mail Address“), process your personal data as part of your use of our products (“Products”) or platform (“Platform” and, together with the Products, “Services”). We deal with your personal data in a confidential and responsible way. The processing of your personal data takes place in compliance with the General Data Protection Regulation („GDPR“) and the Austrian data protection act in its current form.

1.2. In this Privacy Policy we want to provide you with information about the company, the nature, scope and purposes of the data collection and use, trying to offer you an insight into the processing of your personal data.

1.3. For some of our Products we will only process data pursuant to purposes and means you determine. In these cases, we will provide you with separate data processing agreements.

1.4. The controller for the processing of your personal data within the meaning of the GDPR is the Company. You can contact us via mail under the address shown below or via e-mail using the E-Mail Address.

Company address:
paxfiles.com Inh. Martin Klutz
Grenzweg 94
2823 Bad Erlach

2. Data We Process

2.1. General: We process such personal data that you as a user of the Services make available to us, for example upon registration or when using the Services (the „Data“).

2.2. Website Use: If you visit our website, we process only personal data that your browser communicates to our server. We collect the following data, which is necessary for us in order to display the website correctly and guarantee the necessary stability and security:

  • IP-address;
  • date and time;
  • requested site, site from which the request was sent, transmitted data volume;
  • access status/HTTP status code;
  • browser, operating system, interface, language and version of the browser software.

2.3. Registration Data: Upon registration we collect and process the following information:

  • registration details: date of registration, password;
  • personal information: full name; email address; address, zip code, city, region, country;
  • company information: company name, tax ID;
  • payment information (optional):
    • credit card type, last four digits, expiration date;
    • PayPal email address;
    • date of payment, invoice ID, currency, amount;
    • monthly or annual payment.

2.4. Product Use Data: Data processed when using the Services is processed by us only as a processor, not as a controller. Please see the separate data processing agreement for details.

3. Why We Process Your Data

3.1. Purpose: The processing of Data pursues the following purposes (“Purposes”):

  • provide and improve the Services;
  • customer relations management, including newsletters;
  • security and stability of the Services.

3.2. Lawfulness of Processing: The lawfulness of processing (Art. 6 GDPR) stems from:

  • 3.2.1. your consent, where we have asked your explicit consent (para.1 subpara. a GDPR); and
  • 3.2.2. the necessity for the performance of contract fulfillment, as your data is needed for a satisfactory use of the Services (para 1 subpara. b GDPR); and
  • 3.2.3. the necessity for the purposes of the legitimate interests pursued by the Company or by a third party (para 1 subpara. f GDPR).

3.3. Legitimate Interests: The legitimate interests pursuant 4.2.3 are to monitor, analyze and improve the Services, to support you with any to protect the security, integrity, performance and functionality of the Services, and to provide you with advertisements.

4. How We Use And Transfer Your Personal Data

4.1. Use: We use Data that you, as user of the product, have provided us with, only for the Purposes.

4.2. Transfer: We transmit Data to third parties only, if this is (i) necessary for the Purposes, e.g. when we use service providers, (ii) due to a request from a national authority, (iii) due to a court ruling, or (iv) if you have consented beforehand.

5. Storage And Data Safety

5.1. Storage Period: We store your Data as long as you are a registered user of the Product. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.

5.2. Deletion: Data will be deleted if you (a) revoke your consent to the storage (b) Data is not needed to fulfill the user contract concerning the Product anymore, or (c) the storage is or becomes legally impermissible. A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.

5.3. Safety Measures: To avoid unauthorized access to Data and generally secure the Data, we apply the following safety measures: encrypted transmission, an authorization concept, a data backup concept, and physical safety measures for servers. Those safety measures are constantly revised to comply with the latest technological developments.

6. Information About Rights

6.1. Exercise of Rights: To exercise the rights defined in Section 7.2 to 7.8, please send a request via e-mail to the E-Mail Address or via mail to the postal address depicted in Section 1.4.

6.2. Revocation of Consent: You can revoke the consent for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation.

6.3. Right of Access: You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data. The more specific information concerns, among others, processing purposes, categories of Data, potential recipients or the duration of storage.

6.4. Right to Rectification: You have the right to obtain from us the rectification of inaccurate Data concerning you. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification.

6.5. Right to Erasure: Should you decide that you do not want us to process your data any further, please send a request via e-mail to the E-Mail Address or via mail to the postal address depicted in Section 1.4. We will erase your Data immediately and inform you of this process. Should mandatory provisions of law prevent such erasure, we will inform you without undue delay thereof.

6.6. Right to Restriction of Processing: You have the right to obtain from us a restriction of processing of your Data in the following cases:

  • 6.6.1. You make an inquiry pursuant para. 7.4, if you so request;
  • 6.6.2. you are of the opinion, that the processing of your Data is unlawful, but are opposed to an erasure of Data;
  • 6.6.3. you still require the Data for the establishment, exercise or defense of legal claims; or
  • 6.6.4. you have objected to the processing pursuant para. 7.8.

6.7. Right to Data Portability: You have the right to (i) receive your Data in a structured, commonly used and machine-readable format and (ii) transmit those Data to another controller without hindrance from us.

6.8. Right to Object: You have the right to object at any time to the processing of Data.

6.9. Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority (in Austria: Datenschutzbehörde), if you think that the processing of Data infringes applicable law, especially the GDPR.

7. Cookies

7.1. What are cookies?

A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting our website; however, a cookie may store a unique identifier for each logged in user. The cookies we use are essential for the operation of the website, or are used for performance, functionality and security purposes.

For example, cookies allow us to remember things about your visit to our website, such as your preferred language, time zone and other preferences in order to make the site and service easier for you to use.

In order to offer the highest level of usability, performance and security we use both session cookies and persistent cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiration date (unless deleted by the user before the expiration date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

How and why we use cookies and similar technologies

The cookies and similar technologies we use, including web beacons, browser cookies, pixel tags and local shared objects (also called “flash cookies”) all share one goal: to offer, measure and improve all aspects of our service continuously and in various ways. We differentiate between those cookies, which are strictly necessary for access and navigation, others that track usage (performance cookies), remember your choices (functionality cookies), and cookies that provide you with targeted content or advertising.

We use cookies for the following purposes and pursuant to Article 6 para. 1f GDPR:

1. Access and security (Strictly Necessary Cookies)

•          To recognise your computer when you visit our website and to facilitate logging in;

•          To protect your security and fight spam and abuse of our website and service;

•          To prevent unauthorized third parties from accessing your account.

2. Settings (Functionality Cookies)

•          To remember details about your browser, site settings and preferences you have specified related to the use of our website and services (e.g. preferred language or time zone).

3. Analytics and research (Performance Cookies)

•          To help us gain important insights and understand the way people use our website and service;

4. Advertising and marketing (Other Cookies)

•          To personalise the website and service for you

•          To include advertisements, which may be of particular interest to you;

In an effort to properly understand the way people use our website and service, we have implemented a number of analytics partners, including Google Analytics. These partners use cookies in order to gather information and analyse site navigation and how and from which websites users reached our website and service.

We do not release any information collected from our own cookies to any third party providers, expect for the service providers assisting in managing cookies.

What can I do to control how cookies are used?

You can disable the installation of cookies by entering the corresponding settings in your browser software (e.g. in Internet Explorer, Mozilla Firefox, Opera, or Safari). In order to opt-out of Google Analytics, you may install the Google Analytics Opt-Out Program, available here: https://tools.google.com/dlpage/gaoptout

For general information about cookies and how to disable them, please visit www.allaboutcookies.org.

8. Analytics Services

8.1. Google Analytics:

  • 8.1.1. General: This Website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses cookies. The information on your use of the Website created by a cookie, will usually be transmitted to a Google server in the USA and stored there. The Website uses Google Analytics in conjunction with the option „_anonymizeIP()“. This means, that your IP-address will be shortened by Google beforehand within member states of the EU or other members of the Agreement on the European Economic Area. Only in exceptional cases the whole IP-address will be transmitted to a Google server in the USA and shortened there. Any connection with a specific person is therefore precluded and personal data immediately deleted. The IP-address transmitted by your browser within the use of Google Analytics will not be combined with other data held by Google.
  • 8.1.2. Plug-in: You can prevent the collection of data through the cookie concerning your use of the website (incl. your IP-address) as well as its processing of this data by Google, by downloading and installing the following browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en.
  • 8.1.3. Purpose: On behalf of the Website operator, Google will use this information in order to evaluate your use of the Website, compose reports on the website activities, and provide further services to the operator related to the website and internet usage. We use Google Analytics to analyze and be able to constantly improve the use of our Website. Through the statistics we are able to improve our services and make them more interesting for users. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing is Art 6 para 1 subpara f GDPA.
  • 8.1.4. Information on Third-Party Provider:
    Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland,
    Fax: +353 (1) 436 1001;
    Terms: https://www.google.com/analytics/terms/gb.html;
    overview on data protection: https://support.google.com/analytics/answer/6004245?hl=en;
    and Privacy Policy: https://www.google.de/intl/en/policies/privacy/.

9. Changes To This Privacy Policy

9.1. If the Company decides to change this Privacy Policy, it will post those changes directly in the Services. Should the changes be material to you, especially concerning your right to data protection, you need to confirm them.

Last modified: 07 September 2021