1. General information We, Finance Trainer International GmbH and Finance Trainer Luxembourg s.à.r.l., take the protection of personal customer data very seriously and we strictly adhere to the rules of the data protection laws. The following regulations apply to all products and services across all companies of Finance Trainer International GmbH (domicile: Austria) and Finance Trainer Luxemburg (domicile Luxemburg). Responsible authorities The responsible body is the legal entity which alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.). Finance Trainer International GmbH Am Hundsturm 11 1050 Wien Österreich
In order to make our products and services available and to be able to provide them as widely as possible, we exchange the data collected and stored about you within the “Finance Trainer Group”, which consists of Finance Trainer International GmbH and Finance Trainer Luxemburg s.à.r.l., as part of our business activities. For this reason, central processes are not limited to the area of a single company, but extend to the Finance Trainer Group. The two companies of the Finance Trainer Group therefore work together in many areas and act as so-called joint responsible parties in the sense of data protection law.
Coordination between the joint responsible parties In view of the shared responsibility within the Finance Trainer Group, we have defined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. In particular, we have defined how an appropriate level of security and your rights as a data subject are ensured, how we jointly comply with data protection information obligations and how we monitor potential data protection incidents. This also includes ensuring that we fulfil our reporting and notification obligations. We hereby jointly provide you with the information pursuant to Art. 13 and 14 DSGVO. We inform each other immediately and completely if we discover errors or irregularities in connection with the data processing carried out by us. If a data protection impact assessment pursuant to Art. 35 DSGVO is required, this will be carried out jointly by both companies. We are obliged to treat all personal data, other confidential information and data security measures obtained within the scope of joint responsibility as confidential. If data is to be destroyed during ongoing data processing, Finance Trainer International GmbH will undertake the demonstrably data protection-compliant deletion/destruction/anonymisation of data carriers and other materials. Finance Trainer International GmbH is at your disposal as your central contact. You can also assert your rights against Finance Trainer Luxembourg s.à.r.l. If you contact us, we will coordinate within the Finance Trainer Group in order to answer your enquiry and to guarantee your rights as a data subject. 2. For what purposes and on what legal basis we process your data Registration on our website When registering to use our personalised services, some personal data is collected, such as name, address, contact and communication data such as telephone number and e-mail address. If you are registered with us, you can access content and services that we only offer to registered users. Registered users also have the option of changing or deleting the data provided during registration at any time if necessary. The legal basis for the processing of your data is Art. 6 para. 1 lit. b) DSGVO. Website contact Through our website you can contact us and leave your data. This data is processed on the basis of Art. 6 para. 1 letter b DSGVO, provided that your request is related to the fulfilment 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, on the effective processing of the enquiries addressed to us (Art. 6 para. 1 lit. f DSGVO) or on your consent (Art. 6 para. 1 lit. a DSGVO), provided that the enquiry was made. Enquiry by e-mail, telephone or fax If you contact us by e-mail, telephone or fax, your enquiry including all personal data (name, enquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent. In this case, your data will be processed on the basis of Art. 6 para.1 lit.b DSGVO, insofar as your enquiry is related to the fulfilment 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, on the effective processing of the enquiries addressed to us (Art. 6 para.1 lit.f DSGVO) or on your consent (Art. 6 para.1 lit.a DSGVO), provided that the enquiry was made. Registration If you register for our seminars, Cyber*Schools, Education Games (e.g. i28), Knowledge Competitions and Symposia, your personal data will be electronically recorded and processed by us. This data is used exclusively for Finance Trainer purposes, unless it is necessary to transfer it to third parties in connection with our service provision (e.g. for the issuing of external examination certificates). The legal basis for the processing of your data is Art. 6 Para. 1 lit. b) DSGVO. Within the framework of events, this data may be passed on to other participants, sponsors and other third parties of the same event (e.g. list of participants, passing on of participant data to speakers, …). The legal basis for the passing on of your data to third parties is Art. 6 para. 1 lit. a) DSGVO. Receiving information If you give your consent, we will inform you by e-mail newsletter about our events / seminars / training programmes / knowledge competitions and other information relevant to you. The legal basis is your consent in accordance with Art. 6 Para. 1 lit. a) DSGVO. In particular, an unsubscribe link at the end of the respective e-mail is available to you for revoking your consent. In addition, you can send us your revocation of the contact data contained in point 10. If you have taken part in one of our events, we are generally entitled to send you the above-mentioned information on products and services by e-mail. If you are not interested in receiving such information, you can already refuse to receive it in connection with the collection of your personal data. Even later on you have the possibility to object to this data processing at any time by sending an e-mail to the contact data mentioned under point 10. Image recordings in the context of events: At our events, we can create images for documentation purposes and for press and public relations work, which can be published via the Internet, social media and print media. The legal basis for this data processing is our legitimate interest in accordance with Art. 6 para. 1 lit. f) DSGVO. You have the right to object to this processing, which should be addressed to the contact details given in point 10. However, it is to be assumed that our interest in the production and use of the image recordings does not interfere excessively with your rights and freedoms, especially since you have entered public space, the production and use of the photos was pointed out to you in advance and during the event, and care is taken both in the production of image recordings and in the publication of the same to ensure that no legitimate interests of persons depicted are violated. If the rights and freedoms of a person depicted are infringed for reasons worthy of special consideration, we will take appropriate measures to prevent further processing. It is not possible to make them unrecognisable in print media that have already been issued. Deletion on the website or in social media channels will take place within the scope of technical possibilities. Online training, certification and graduate lists For online trainings (Cyber*School, Mobile App, Education Games like i28, etc.) and certifications (e.g. Certified ALM Manager) “Halls of Fame” or graduate lists with your first and last name will be published. The legal basis is your consent in accordance with Art. 6 Para. 1 lit. a) DSGVO. ALM Forum If you would like to receive the ALM Forum offered on the website, we need 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 that you agree to receive the ALM Forum. Further data is not collected or only collected on a voluntary basis. We do not pass this data on to third parties. The data entered in the registration form will be processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the ALM Forum at any time. The legitimacy of the data processing operations already carried out remains unaffected by the revocation. 3. Who receives your data? Within the Finance Trainer Group, only departments or employees will receive your data if they need them to process them for the relevant purposes. (Accounting, bookkeeping, organisation of face-to-face seminars, marketing, Cyber*School access and support). In addition, your data may be passed onto processors commissioned by us (IT service providers, printing services, marketing etc.) Your data may also be passed onto third parties if they require the data to fulfil their respective services. All contract processors have been carefully selected and take appropriate technical and organisational measures to ensure that your data is processed in accordance with data protection obligations and that your rights are protected. In particular, the processors are not permitted to use your personal data for their own purposes. If cooperation partners/sponsors are named in the invitation to tender for an event, the participants grant in this case revocable consent to pass on their personal data (in particular name, e-mail address, company) to the cooperation partners/sponsors named in the invitation in order to be used by them. This consent can be revoked at any time by sending an informal e-mail to Finance Trainer. In this case, we are obliged to forward the revocation directly to the cooperation partners concerned so that they can implement it. This data forwarding concerns in particular the sponsors of the Alpbach Financial Symposium, which can be viewed at www.alpbacherfinanzsymposium.com/sponsoren. 4. How long will your data be stored? We process your personal data for as long as necessary to keep you informed, to send you participant confirmations or certificate of performance for the topics of our events and seminars. In addition, we comply with statutory storage and documentation obligations, which result from the General Civil Code (ABGB) and the Business Code (UGB), among others, or for the assertion, exercise or defence of legal claims. As a matter of principle, your data will therefore be deleted after revocation of your consent or your objection, provided that storage is not required to fulfil a legal obligation or to assert, exercise or defend legal claims. Further processing will then only take place if you have expressly consented to the further use of your data or if we have reserved the right to carry out further data processing which is permitted by law. It is possible that instead of deleting the data, it may be made anonymous. In this case, any personal reference is irretrievably removed, which is why the obligations to delete data under data protection law do not apply. 5. What rights do you have? Revocation of your consent to data processing Many data processing operations are only possible with your express consent. You can revoke any consent already given at any time. The legality of the data processing carried out up to the time of revocation remains unaffected by the revocation. Right to object to data collection in special cases and for direct advertising (Art. 21 DSGVO) If data processing is carried out on the basis of Art. 6 para. 1 letter f DSGVO, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation. The respective legal basis on which processing is based can be found in this data protection declaration. If you lodge an objection, we will no longer process your personal data concerned unless we can prove compelling reasons for processing which outweigh your interests, rights and freedoms or unless the processing serves to assert, exercise or defend legal claims (objection in accordance with Art. 21 Par. 1 DSGVO). If your personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; if you object, your personal data will no longer be used for the purpose of direct marketing (objection under Art. 21 para. 2 DSGVO). 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 in a common, machine-readable format. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time at the address given in the imprint. Information, deletion and correction Within the framework of the applicable legal provisions, you have the right to obtain information free of charge at any time about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correct or delete this data. For this purpose, as well as for any further questions regarding personal data, you can contact us at any time using the contact details given under point 10. Right to restrict processing You have the right to request that the processing of your personal data be restricted. To do so, you can contact us at any time using the contact details given in point 10. The right to limit the processing of your personal data exists in the following cases: • If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the review, you have the right to request that we limit the processing of your personal data. • If the processing of your personal data was/is carried out unlawfully, you may request the restriction of the processing of your data instead of its deletion. • If we no longer need your personal data, but you need it for the exercise, defence or assertion of legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion. • If you have lodged an objection in accordance with Art. 21 Paragraph 1 DSGVO, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to demand the restriction of the processing of your personal data. • If you have restricted the processing of your personal data, such data – apart from being stored – may only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.
6. Right of appeal to the competent supervisory authority If you believe that the processing of your data violates data protection law or that your data protection rights have otherwise been violated in any way, you can lodge a complaint with the supervisory authority. In Austria, the data protection authority is the competent authority. In Luxembourg, the National Commission is responsible for data protection. Österreichische Datenschutzbehörde Barichgasse 40-42, 1030 Wien Telefon: +43 1 52 152-0 E-Mail:
Nationale Kommission für den Datenschutz 15, Boulevard du Jazz L-4370 Belvaux Luxemburg Tél. : (+352) 26 10 60 -1 E-Mail:
Misprints and changes reserved, place of jurisdiction Vienna / Luxembourg Version 3: 15.09.2020