1. General points
For SAVD Videodolmetschen GmbH (shortened to SAVD in the following), the topics of data protection and information security are the basis for stable and successful customer relationships and are given high priority within the company. For this reason, the protection of your personal data (“data” in the following) is a particular concern.
When handling data, we follow all relevant regulations – in particular those in the General Data Protection Regulation (GDPR) and the Telecommunications Act (TKG Austria) – in their respective valid versions. We have also taken the necessary technical and organisational measures to ensure an appropriate level of data protection.
In the following, we would like to inform you in more detail about which data is collected during your visit to our websites www.savd.at, www.videodolmetschen.com, www.phrasix.com and www.stti4all.com and all their subdomains/pages (“website” in the following, referring to these individually or as a group), and when using our offers, and how this is processed and used by us afterwards.
When you use our website only to retrieve information, it is generally not necessary for you to provide personal data. When operating the website, however, it is necessary to process certain data which can be used to establish a connection with a person. In this case, this is the data which is transmitted to us by your internet browser. This data includes the following, in particular:
- Date and time of access to our website
- Your browser type
- The browser settings
- The operating system used
- The last site you visited
- The volume of data transferred and the access status (file transferred, file not found, etc.)
- Your IP address
This is done to allow access and use of the website you have accessed in the first place, for statistical purposes and to improve our internet offer.
The legal basis for this is our legitimate interest in accordance with point (f) of Art. 6(1) GDPR to guarantee the running of the website, to perform error and availability analysis and to defend against attacks.
At most, the recipients of your data are processors, but not third parties.
The data is only stored for a maximum of four weeks provided there is no legal obligation to store it beyond this point. At the same time, we may store the data for longer than this to the extent that it is necessary to investigate any ascertained attacks on our website.
3. Individual processing
a. Making contact
If you contact us by email or telephone, the data you enter will be used for handling your enquiry and stored by us in case of follow-up questions.
The legal basis for the processing is, on one hand, our legitimate interest in accordance with point (f) of Art. 6(1) GDPR in answering your enquiry, or the contract initiation or fulfilment in accordance with point (b) of Art. 6(1) GDPR.
The data is only stored for the length of time necessary to achieve the relevant purpose, or within the framework of statutory retention periods.
b. Business relationships
Depending on the contract, it is necessary to process certain data in order for you make use of the relevant service or, on our side, to perform the relevant service.
We process the data which is necessary for initiating a contract (quote preparation, participation in tenders etc.).
Data is also processed as part of ongoing business relationships which are necessary for us to perform our services, for customer support and information, including internal documentation and administration. In addition, data is also stored in order to meet statutory obligations (in particular the Federal Taxation Regulations (BAO)) and, where applicable, to assert and defend against legal claims.
In this case, the following legal bases apply:
- The initiation or fulfilment of a contract – point (b) of Art. 6(1) GDPR.
- The fulfilment of statutory obligations – point (c) of Art. 6(1) GDPR.
- Legitimate interest in documentation in order to assert and defend against legal claims – point (f) of Art. 6(1) GDPR.
The data is generally only stored for the length of time necessary to fulfil the mutual contractual obligations.
In order to meet the statutory obligations (particularly Section 132 BAO, Sections 190, 212 UGB), the data is stored for a duration of 7 years from the end of the relevant calendar year. In certain cases, such as for the assertion and defence of legal claims, the data may be retained for longer. Contracts and the associated data above all are retained for 30 years based on the general limitation period in accordance with Section 1489 of the Civil Code of Austria (ABGB). Up until the point of erasure, the data is restricted until then so that no further processing or access takes place. In certain cases, the data may be retained for longer, in particular for the assertion and defence of legal claims.
In order to be able to perform our services, we make use of various contract or business partners, where applicable. These partners cooperate in delivery or services. They are contractually or statutorily obliged to maintain confidentiality. Your data is also passed to authorities or courts, to the extent that we are legally obliged to do so.
c. Customer language portal
When you use the portal, you can use the services of our video interpreters directly. Once you have successfully registered, you have the option of calling the desired language or alternatively, contacting our service hotline.
The following data is processed in this context: IP address, customer ID, username, password, time and date of the (video) call, language, conversation partner.
The legal basis for the processing is the fulfilment of our contact with you to provide video interpreting (point (b) of Art. 6(1) GDPR).
The processed data is only stored for the length of time required based on statutory requirements (provisions on damage claims, among others).
Telehealth allows audio-visual communication between users via our platform.
The following data is processed in this context: IP address, customer ID, username, password, time and date of the (video) call, language, conversation partner.
As the data controller, we only process our customers’ data for billing purposes. We are the processors for other data processing activities.
The legal basis for the processing is the fulfilment of our contract with our customers (e.g. doctors, penal institutions) to provide telehealth.
The processed data is only stored for the length of time required based on statutory requirements (provisions on damage claims, among others). The billing data is retained for up to seven (7) years.
e. Application process
The personal data transmitted by you in the course of your job application (including correspondence) is processed for entry and storage, as well as for coordination and evaluation in the application process. With your consent to keep your data on file, it may also be used for later application processes.
We also carry out an anonymous statistical evaluation of the applicant structure. If you do not provide your data, it is not possible for us to consider your application during the application process, as otherwise we cannot judge whether you are well suited to the relevant role.
The legal basis is the implementation of pre-contractual measures within the meaning of point (b) of Art. 6(1) GDPR. We store your data for eight months after completion of the application process, and base this on our legitimate interest in asserting and defending against legal claims. In the case of keeping data on file, the legal basis is your express consent within the meaning of point (a) of Art. 6(1) GDPR.
Once the application process is complete, the personal data transmitted by you is erased after eight months. In certain cases, the data may be retained for longer, in particular for the assertion and defence of legal claims.
f. Taking photographs and recording videos at company events
As is common practice at any event, photographs and/or videos are produced at the events organised by us. This is not a matter of identifying individual persons, but purely about documenting the event. For the purposes of documentation, the photographs and/or videos produced by us are stored securely and, if applicable, also made public online (on our homepage), in our company magazine or via newsletters. Furthermore, these are also stored for archive purposes. It may be the case that we present the photographs/videos produced at future events (e.g. annual/anniversary events).
The processing (production, presentation and publication of the photographs/videos) is based on our prevailing legitimate interest to document our own events and retain the documentation in an archive (point (f) of Art. 6(1) GDPR). This also covers the interest in informing the public, customers and interested parties about our company’s events, and to document our own company history with photographs and video recordings for future generations.
The photographs/videos produced are stored for the length of time necessary for the purpose. Photographs/video recordings are generally erased immediately if they are not suitable for the purpose specified above, if the legitimate interests of the pictured person would be violated, or in the case of the data subject’s objection.
There is generally no obligation to be photographed or recorded. If you do not agree to the taking of these photographs/videos or their publication, please inform the photographer on site. You can also contact us once the photograph/video has already been taken. For more information, see your right to object below.
g. Management of requests for the rights of data subjects
The purpose is the processing of your requests in connection with the rights of data subjects according to GDPR. We also store this data beyond the point when the request is completed, so that we can prove that we met our statutory obligation to handle your request in a timely and appropriate manner.
The legal basis for the processing of your requests is Art. 12 et. seq. GDPR. This states that we must transmit all communications in connection with your rights as a data subject. The storage of data beyond the completion of the request takes place on the basis of our legitimate interests according to point (f) of Art. 6(1) GDPR, where this interest arises from the purpose stated above.
Your data is stored for three years once the request has been completed. This is based on the general limitation period in accordance with Section 24 Paragraph 4 DSG. Up until the point of erasure, the data is restricted until then so that no further processing or access takes place.
4. Your rights
If your personal data is processed (collected, recorded, stored, analysed, altered, read, queried, disclosed, disseminated, aligned, combined, restricted, erased or destroyed), you are the data subject within the meaning of GDPR. As a data subject, you have the following rights with regard to the controller who is processing your personal data:
In accordance with Art. 15 GDPR, you have the right to make an information request and demand information about all data concerning you which is processed within the company. In this case, information must be provided about this data. You also have the right to obtain the following information:
- The purposes of processing.
- The categories of personal data processed.
- The recipients or categories of recipients to whom the personal data has been or will still be disclosed, especially for recipients in third countries or for international organisations.
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.
- The existence of the right to request from the controller rectification or erasure of personal data concerning you or restriction of processing of personal data concerning you or to object to such processing.
- The existence of the right to lodge a complaint with a supervisory authority.
- Where the personal data is not collected from you, any available information as to its source.
- The existence of automated decision-making including profiling and – at least in these cases – meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for you.
- Suitable guarantees in accordance with Art. 46 GDPR if personal data is transmitted to a third country or to an international organisation.
In accordance with Art. 16 GDPR, you have the right to demand that we rectify and/or complete the incorrect personal data concerning you without undue delay.
According to Art. 17 GDPR, you have the right to demand that the personal data concerning you is erased without undue delay. The controller is obliged to erase personal data without undue delay, provided one of the following reasons applies:
- The personal data is no longer required for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which processing is based according to point (a) of Art. 6(1) or point (a) of Art. 9(2) GDPR, and there is no other legal ground for the processing.
- You object to the processing according to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing. Or you object to the processing pursuant to Art. 21(2).
- Your personal data has been unlawfully processed.
- The personal data is to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data was collected in relation to information society services offered according to Art. 8(1) GDPR.
The right to erasure does not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information,
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller,
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Art. 9(2) as well as Art. 3 GDPR,
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89(1) GDPR in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
- for the assertion, exercise or defence of legal claims.
Where the controller has made your personal data public and is obliged to erase it, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that a data subject has requested the erasure by such controllers of any links to, or copy or replication of, this personal data.
In accordance with Art. 18 GDPR, you have the right to request the restriction of processing if:
- you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data,
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of use of the personal data instead,
- the controller no longer needs your personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims, or
- you have objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override yours. Where processing of the personal data relating to you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the assertion, 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 Union or of a Member State. Where you have obtained restriction of processing, you shall be informed before the restriction of processing is lifted.
If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to communicate such rectification or erasure of the data or restriction of processing to each recipient to whom your personal data has been disclosed. This is the case unless it proves impossible or involves disproportionate effort.
You have the right to receive any personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where
- the processing is based on consent pursuant to point (a) of Art. 6(1) or point (a) of Art. 9(2) GDPR or on a contract pursuant to point (b) of Art. 6(1) GDPR, and the processing is carried out by automated means.
You also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The right to data portability does not apply to any personal data processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The rights and freedoms of others must not be adversely affected.
According to Art. 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you that is based on points (e) or (f) of Art. 6(1) GDPR. The right to object can therefore be asserted when the processing
- is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or
- is necessary for safeguarding the legitimate interests of the controller or a third party, provided your interests, fundamental rights and freedoms requiring the protection of personal data do not override these (particularly in cases involving children)
- where the controller can demonstrate no compelling legitimate grounds for the processing, as your interests, rights and freedoms override these or where the processing is not necessary for the assertion, exercise or defence of legal claims.
Withdrawal of consent
You have the right to withdraw your consent to any processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you believe that the processing of your personal data infringes applicable data protection legislation, or that your legal claim to data protection may be violated in some way, please get in touch with us.
This will allow us to handle your concerns. However, you also have the right to contact the responsible data protection authority. The authority responsible for us is the Österreichische Datenschutzbehörde (Austrian Data Protection Authority), Barichgasse 40-42, 1030 Vienna, Austria. In accordance with Art. 77(1) GDPR, you can also contact the data protection authority at your place of residence, workplace or at the place the violation is alleged to have happened.
Your trust is especially important to us. If you have any further questions about data protection, feel free to use the following contact options:
SAVD Videodolmetschen GmbH
External data protection officer:
x-tention Informationstechnologie GmbH
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Date: 22 March 2022