Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

Last updated: November 17, 2025

Table of Contents

Controller

ARGE Sigma 9
Musterweg 9
9345 Wolfsberg

E-Mail Address: office@sigma9.studio

Overview of Processing Activities

The following summary outlines the types of data processed, the purposes of their processing, and refers to the data subjects.

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Applicable Legal Bases

Applicable legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. This includes, in particular, the Federal Act concerning the Protection of Personal Data (Datenschutzgesetz – DSG). The DSG contains special provisions on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes, and transfer, as well as automated individual decision-making.

Note on the applicability of GDPR and Swiss DPA: This privacy notice serves to provide information under both the Swiss Federal Act on Data Protection (DPA) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used for broader spatial application and comprehensibility. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss DPA, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of the terms will continue to be determined by the Swiss DPA within its scope of application.

Applicability of data protection regulations in the country of domicile: In the country where the controller is domiciled, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, considering the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transferring data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or if explicitly mentioned in the privacy policy), this is always done in compliance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual protection ensures comprehensive security for your data: The DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should there be any changes to the DPF, the Standard Contractual Clauses will act as a reliable fallback option. This way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding security measures apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no other legal bases for processing exist. This applies to cases where the original purpose of processing ceases to exist or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that apply specifically to certain processing activities.

If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies. Data that is no longer kept for its originally intended purpose but is retained for legal or other reasons will be processed exclusively for the reasons that justify its retention.

Start of the period at the end of the year: If a period does not explicitly start on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships under which data is stored, the triggering event is the date on which the termination or other conclusion of the legal relationship becomes effective.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

Provision of the Online Offering and Web Hosting

We process users' data to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

Further information on processing processes, procedures, and services:

Use of Cookies

The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, such as for the functionality, security, and comfort of online offerings, as well as for creating analyses of visitor flows. We use cookies in accordance with legal regulations. For this, we obtain the user's consent in advance where necessary. If consent is not required, we rely on our legitimate interests. This applies when the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We clearly inform about their scope and which cookies are used.

Information on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

General information on revocation and objection (opt-out): Users can revoke their given consent at any time and also object to processing in accordance with legal requirements, including through the privacy settings of their browser.

Further information on processing processes, procedures, and services:

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, telephone, or via social media) and within existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.

Further information on processing processes, procedures, and services:

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). This can include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the user's IP address, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, but may also be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Further information on processing processes, procedures, and services:

Data Protection Information for Whistleblowers

This section provides information on how we handle data from individuals who provide tips (whistleblowers), as well as from affected and involved parties, as part of our whistleblower procedure. Our goal is to provide a straightforward and secure way to report possible misconduct by us, our employees, or service providers, especially for actions that violate laws or - This text area must be unlocked with a premium license. -

Legal bases (Austria): Insofar as we process data to fulfill our legal obligations under the Whistleblower Protection Act (HSchG), the legal basis for processing is Article 6(1)(c) GDPR and, in the case of special categories of personal data, Art. 9(2)(g) GDPR, each in conjunction with § 8 HSchG. This relates to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal duties, and, in the case of using the data collected in the reporting procedure, taking further investigative or labor law measures against persons convicted of a violation.

Insofar as we process data (especially in cases of identified misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in legally compliant and ethical conduct in accordance with Art. 6(1)(f) GDPR.

If you have given us consent to process personal data for specific purposes, the processing is based on this consent pursuant to Art. 6(1)(a) GDPR and, in the case of special categories - This text area must be unlocked with a premium license. -

Types of data processed:

In the course of receiving and processing tips, as well as in the subsequent whistleblower procedure, we may collect various data. This includes, in particular, the data provided by a whistleblower, such as:

For the purposes of fact-finding and further proceedings, we also process the following personal data:

Special categories of personal data:

It may happen that we collect special types of personal data in the course of our activities, especially if they are communicated by a whistleblower. These include:

This data is only processed if it - This text area must be unlocked with a premium license. -

Use of our online forms: Please note that it is possible to submit tips anonymously. To ensure the security of your data when using our online forms, we recommend opening them in your browser's 'incognito mode'. Here's how to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When you visit our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is temporarily stored in a log file and automatically deleted after 30 days at the latest.

The processing of the IP address serves technical and administrative purposes of establishing a connection to our website. It ensures the security, stability, and functionality of the whistleblower form and is an important part of our measures to ensure confidential - This text area must be unlocked with a premium license. -

Providing names: You have the option to submit tips anonymously. However, unless prohibited by national legislation, we recommend providing your name and contact details. This allows us to investigate the report more effectively and, if necessary, contact you directly.

If you provide your name and contact details, your identity will be treated with strict confidentiality. Exceptions to this confidentiality only exist if we are legally obliged to disclose your identity. This may be necessary to protect our rights or the rights of our employees, customers, suppliers, or business partners - This text area must be unlocked with a premium license. -

Provision of data to third parties: Data related to the submitted tips will only be passed on to third parties under certain circumstances. This happens either a) if you have given us your express consent, or b) if there is a legal obligation to disclose the data. Possible third parties include public authorities, government, regulatory, or tax authorities, if the disclosure is necessary to fulfill a legal or regulatory obligation. In addition, we may engage lawyers and other professional advisors in accordance with legal provisions. They are authorized to investigate suspected misconduct and take necessary measures after an investigation, such as initiating disciplinary or legal proceedings. Furthermore, carefully selected and monitored service providers may receive data for these purposes (e.g., operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations as part of a data processing agreement.

Data retention and deletion: Personal data is only processed for as long as is necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations, however, the data may be retained for longer to meet legal requirements, as long as this is necessary and proportionate. In such cases - This text area must be unlocked with a premium license. -

Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes. The incoming tips are processed by authorized persons who have access to the respective tips and carry out the subsequent verification of the facts. Our employees are specially - This text area must be unlocked with a premium license. -

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and we ask you to check the information before contacting them.

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

Created with the free Privacy Policy Generator by Dr. Thomas Schwenke