Privacy Policy

This privacy policy was last updated: 29.06.2023

1. Preamble

Glacier Carbon Reduction GmbH (hereinafter "Glacier" or "we") is the organizer of Climate Impact Day, the Climate Ranger Academy, and operator of a digital platform for carbon reduction (hereinafter the "Services"), as well as this website.

For these purposes, we process personal data. Personal data is any information relating to an identified or identifiable person, such as name, date of birth, address but also the content of email correspondence or behaviour on websites (hereinafter "personal data" or "data"). Among the personal data, there are special categories that are particularly protected by law. These include, for example, data on religious beliefs or health data.

The protection of your personal data is of particular importance to us and we process it exclusively on the basis of the legal provisions of the EU General Data Protection Regulation 2016/679 ("GDPR"), the Data Protection Act 2018 ("DPA 2018"), as well as the Telecommunications Act ("TKG 2003").

In this privacy notice, we inform you about the most important aspects regarding the processing of personal data.

2. Data controller

In the context of data processing, Glacier acts as the data controller within the meaning of Art. 4 lit 7 DSGVO. The role of the data controller is characterized by the fact that the controller decides on the purpose and means of the processing of personal data. The controller within the meaning of the GDPR is:

Glacier Carbon Reduction GmbH
Address: Schönbrunner Straße 131 Top 2.03, 1050 Vienna
Company register number: FN540361z
Place of jurisdiction: Commercial Court of Vienna
E-mail: hello@glacier.eco

3. Scope, nature, and purpose of data processing

As a matter of principle, we only collect and use personal data if this:

• is necessary for the establishment, administration and processing of pre-contractual measures, compliance with contracts or for the provision of our services;
• is necessary to comply with legal requirements or we are required to do so by law;
• happens with the consent of the data subject; or
• is justified on the basis of our legitimate interests.

Glacier processes personal data from you if you provide this data in the context of a registration, contact initiation, business correspondence, or contract processing. This data includes, among other things, contact data (e.g. name, e-mail address, telephone number), company data (e.g. company, position, number of employees), correspondence data (e.g. content of e-mails, letters), and transaction data (e.g. offers, contract documents, invoices).

This personal data is processed for the purpose of contract initiation and processing, as well as for internal company administration. The transmission of personal data is necessary for this purpose, as otherwise a contract cannot be initiated or processed.

In the paragraphs from § 6 onwards, we describe in detail the individual processing activities in connection with our website. It should be noted that not every processing activity described below is necessarily carried out in relation to all data subjects.

4. Disclosure of data to third parties

We only disclose personal data to third parties (hereinafter referred to as "recipients") if and insofar as this is necessary and permissible. Details on the respective recipients can be found below under the individual data processing operations (see § 6). We may also need to disclose your personal data to a competent authority or a competent court if we are obliged to do so.

In addition, we sometimes use external service providers (so-called "data processors") who process personal data on our behalf. These have been carefully selected by us and are bound by our instructions. If we use processors, they are named in the "Recipients" section of the respective processing activity. In addition, we conclude so-called Data Processing Agreements with all data processors.

5. Your rights

Applicable data protection law grants you comprehensive rights with regard to the processing of your personal data, about which we would like to inform you in the following paragraphs. To exercise these rights, please contact hello@glacier.eco. If you wish to unsubscribe from any email correspondence, you can do so directly in the newsletter itself by unsubscribing or changing your subscription preferences.

Right to information

You have the right, on request and free of charge, to obtain confirmation from us as to whether we are processing personal data about you, to obtain information about the personal data we are processing about you, to obtain further information about Glacier's data processing, and to obtain copies of such personal data we are processing about you.

Right of rectification

In addition, you have the right to correct inaccurate and complete incomplete personal data that we hold about you, as well as the right to the immediate deletion of the personal data concerning you or, insofar as further processing is required pursuant to Art 17 (3) GDPR, to restriction of processing (in terms of Art 18 GDPR). Glacier will delete your personal data as soon as they are no longer required for the provision and billing of the services.

Right to erasure or restriction

In addition, you have the right to object to the further use of your personal data in the future or to restrict such use at any time, in case it is processed in accordance with Art 6 (1) (f) GDPR to protect the legitimate interests of the controller or a third party.

However, we would like to point out that the deletion of personal data immediately after the purpose of its storage has ceased to exist, as well as your right to demand the deletion of your personal data, may be restricted by statutory retention obligations (in particular § 212 UGB and § 132 BAO).

Supervisory authority

You also have the right to lodge a complaint with the Austrian Data Protection Authority (www.dsb.gv.at) if you believe that your personal data is being processed by us in breach of data protection regulations.

6. Data Processing in Detail

6.1. Visits to our Website

Description, scope, and purpose: When you visit our website, we process a minimum amount of personal data in the form of server log files as well as cookies and website analytics to provide the website and to ensure its functionality and relevance. In addition, we also integrate third-party content (such as YouTube videos or podcasts). In the following section, we will give you a brief insight into how the processing of personal data for these purposes works:

Server log files

In part, our system automatically collects data and information from the computer system of the retrieving device, e.g. your computer or mobile phone. We use this data to provide the website and to create so-called log files about the access requests to our website. Log files are stored to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our IT systems. Under no circumstances is the data from server log files used for marketing-related purposes.

The temporary storage of the IP address by the system is necessary to enable the delivery of the website to the user's device. For this purpose, the user's IP address must remain stored for the duration of the session. In addition to the IP address, we collect the following information, among others: Browser type and version used; Language and version of the browser software; user's operating system; user's internet service provider; user's IP address; date and time of access; the volume of data transmitted; websites from which the user's system accesses our website; and websites accessed by the user's system via our website. The data is also stored in the log files of our system.

This data is not stored together with other personal data of the user.

Cookies & Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. This is done anonymously, without identifying the user of the site personally. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

Google will not associate your IP address with any other data held by Google. 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.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

The data sent by our website and linked to cookies, user IDs, or advertising IDs are automatically deleted by Google after 14 months (once a month). You can prevent the collection of data generated by cookies and related to your use of the website (incl. your IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link.

Integration of third-party services and content

We also use third-party content or services on this website. Specifically, we include videos from YouTube, podcasts from Spotify and fonts from Google. You can find out more details about how they process your personal data on their privacy statements.

In order to integrate content and services (such as videos or podcasts), these third-party providers must retrieve the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is therefore necessary for the display of this content. We aim to only use content whose providers only use the IP address to deliver the content.

The legal basis for the temporary storage of log files, as well as the use of cookies and analytics, is our legitimate interest pursuant to Art. 6 (1) lit. (f) GDPR, which lies in the pursuit of the above-mentioned purposes, in particular in analyzing and ensuring the relevance and functionality of the website and guaranteeing the security of our IT systems. The integration of third-party services and content is also based on our legitimate interest (Art. 6 para. 1 lit. (f) GDPR), which lies in the optimization and economic operation of our online offer.

Retention period: Personal data is generally deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of personal data for the provision of the website, this is the case when the respective session has ended. Server log files are stored for a maximum of 60 days to ensure the operational security and integrity of our systems.

Possibility of revocation: The collection of personal data to provide the website and the storage of personal data in log files is necessary for the operation of the website. You can therefore only exercise your right to object by not visiting the website.

6.2. Submissions of the contact form

Description, scope, and purpose: As the organizer of the Climate Impact Day and the Climate Ranger Academy and operator of a digital platform for carbon reduction, we offer you the opportunity to get in touch with us on this website in the form of the contact form in order to give us the opportunity to contact you. For this purpose, we ask you as a representative of your company to provide us with personal data consisting of contact details (first name, surname, e-mail address, telephone number) and company data (company, position, number of employees). If this personal data is not provided or not provided in full, we may not be able to contact you, may not be able to fulfill our (pre-)contractual obligations in full, or may not be able to enter into a contractual business partnership.

Legal basis: The processing of the personal data provided within the contact form is necessary for responding to your request and/or the initiation of the contractual relationship.

• The legal basis for processing activities is therefore the implementation of pre-contractual measures, as well as subsequently the fulfillment of the contract pursuant to Art. 6 para. 1 lit. (b) GDPR, or is based on our legitimate interest, which lies in particular in maintaining our business contacts (Art. 6 para. 1 lit. (f) GDPR).
• The legal basis for processing activities in connection with the control, monitoring, and improvement of internal processes is our legitimate interest, which lies in particular in promoting our company, improving our business processes, as well as supporting our management in complying with the due diligence obligations incumbent upon it (Art. 6 para. 1 lit. (f) GDPR).
• The legal basis for processing activities within the scope of our document management and our contract database is our legitimate interest, which lies in having the technical infrastructure available to facilitate the selection of contractual partners for future business and the preparation and execution of contracts (Art. 6 para. 1 lit. (f) GDPR).
• The legal basis for processing activities that are required to comply with legal provisions is the fulfillment of legal obligations (Art. 6 para. 1 lit. (c) GDPR).

Retention period: Personal data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In addition, your personal data will be retained for documentation and evidence purposes if we are legally obliged to do so or if this appears necessary. If applicable, the personal data will be deleted earlier if you permissibly exercise the options of objection and removal.

Possibility of revocation: You may object to processing activities that are based on our legitimate interest (Art. 6 para. 1 lit. (f) DSGVO). If you object to the processing of your personal data for our contract partner management, your personal data will be deleted from our databases if there is no ongoing contractual relationship with you and there is no other legally permissible reason for further storage.

6.3. Newsletters

Description, scope, and purpose: We send newsletters, e-mails, and other electronic notifications with information (hereinafter "newsletters"). The purpose of these newsletters is to provide you with valuable information about our services and the topic of carbon reduction. In addition to the personal data you provide when registering for the newsletter, we also store your IP address and the times of registration and confirmation for the purpose of verifying your registration and, if necessary, clarifying any possible misuse of your personal data. With regard to the specific newsletter you receive, we collect and process the time when you receive the newsletter, the time when you open and read the newsletter, your click behavior, and whether you forward the newsletter, if applicable. This processing is carried out for the purpose of improving our services and to be able to continuously adapt the newsletter content to the needs of the newsletter subscribers.

Legal basis: The legal basis for the processing of personal data in connection with the newsletter registration and dispatch is your consent pursuant to Art 6 (1) (a) DSGVO, and with regard to the processing of your IP addresses and times of registration and confirmation, our legitimate interest pursuant to Art 6 (1) (f) DSGVO, which lies in the purposes described above, in particular in the proof of your registration and in the clarification of possible cases of abuse.

Retention period: In principle, we retain your personal data for as long as you are registered for the newsletter. You can unsubscribe from the newsletter yourself at any time and thus end the retention of your data in this context.

Revocation option: You are entitled to revoke your consent at any time and unsubscribe from the newsletter. However, this does not affect the lawfulness of the processing carried out up to the time of the revocation. To exercise your right to revoke consent, click on the corresponding link contained in each newsletter to unsubscribe.

6.4. Climate Impact Challenge

Description, scope, and purpose: Together with trend, the business magazine of VGN Medien Holding GmbH (Taborstraße 1-3, 1020 Vienna), we are conducting the "Climate Impact Challenge", in the course of which we are looking for the most creative and effective solutions forCO2 reduction. For this purpose, we ask you as a representative of a company to provide us with personal data consisting of contact details (first name, last name, e-mail address) and company data (company, position, address, as well as information on products and services). The processing of the personal data provided in the form for participation in the "Climate Impact Challenge" is a prerequisite for participation in the Challenge.

Legal basis: The legal basis for the processing of personal data in connection with the "Climate Impact Challenge" is your consent pursuant to Art 6 para 1 lit (a) GDPR, as well as our legitimate interest pursuant to Art 6 para 1 lit (f) GDPR.

Retention period: Personal data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In principle, we, therefore, retain your personal data for as long as it is required for the execution of the "Climate Impact Challenge".

Possibility of revocation: You are entitled to revoke your consent at any time and to terminate your participation in the "Climate Impact Challenge". However, this does not affect the lawfulness of the processing carried out up to the time of the revocation. To exercise your right to withdraw consent, please send an email to hello@glacier.eco.

7. Recipients

The personal data you provide to us will be disclosed to IT service providers whose services we use to manage our business contacts, to carry out pre-contractual and contractual measures, as well as for newsletter distribution, communication, and document management.

SiteGround

The personal data we use in the processing of server log files is processed by our hosting provider SiteGround Spain S.L.. (Calle de Prim 19, 28004 Madrid, Spain) ("SiteGround") on our behalf. For this purpose, we have concluded a "Data Processing Agreement" with SiteGround.

Server log files are stored by SiteGround in data centers in Germany. A transfer to countries outside the EU does not take place.

HubSpot

In order to carry out pre-contractual and contractual measures, as well as for the management of our business contacts and the dispatch of our newsletters, we use the integrated customer relationship management (CRM) software HubSpot from the company HubSpot Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, USA) from the USA with several branches in Europe.

HubSpot processes and stores this information on our behalf. We have concluded a "data processing agreement" with HubSpot for this purpose. HubSpot processes and secures data via the Google Cloud Platform (GCP) in the EU and then transfers it to the USA for storage on Amazon Web Services (AWS) servers.

In order to guarantee the protection of personal data during the transfer of data from the EU to the USA, HubSpot has undertaken to comply with the "standard contractual clauses" adopted by the EU Commission and to process personal data of European citizens exclusively in accordance with these standard contractual clauses of European standards. These standard contractual clauses are also provided for in the Data Processing Agreement that we have concluded with HubSpot.

Microsoft

For our business communication and document management, we use "Microsoft Office 365" of the company Microsoft Corp. (One Microsoft Way, Redmond, WA 98052-6399, USA) ("Microsoft") from the USA with a branch in Austria. Microsoft processes and stores this information on our behalf. We have concluded a "Data Processing Agreement" with Microsoft for this purpose.

Data related to business communications and the management of our documents are processed and stored by Microsoft in the EU. A transfer to countries outside the EU is not planned. However, should a transfer outside the EU become necessary, this will be done in compliance with state-of-the-art encryption technologies, for a limited period of time and within the framework of the European Standard Contractual Clauses (SCCs).

Google

For web analysis, we use the "Google Analytics" service of the company Google LLC (1600 Amphiteatre Parkway, Mountainview, CA 94043, USA) ("Google") from the USA with a branch in Ireland. Google processes and stores this information on our behalf. We have concluded a "Data Processing Agreement" with Google for this purpose.

Data in connection with web analytics is processed and stored by Google in the EU. A transfer to countries outside the EU does not take place.

VGN Medien Holding GmbH

For the "Climate Impact Challenge" (CIC) we are working together with trend, the business magazine of VGN Medien Holding GmbH (Taborstraße 1-3, 1020 Vienna). Together we select the most creative and effective solutions for CO2 reduction. For this purpose, we will share the submissions with trend via the form. In addition, trend will also report editorially on these solutions at its own discretion and, if necessary, contact the submitting companies for this purpose.

VGN Medien Holding GmbH, Taborstraße 1-3, 1020 Vienna, is responsible for the data processing of the trend within the meaning of the DSVGO. Contact for exercising all data subject rights is via datenschutz@vgn.at or you can contact VGN Medien Holding GmbH, Attn: General Secretariat, Taborstraße 1-3, 1020 Vienna by post.

Only the data received from Glacier that is necessary for the implementation of the Climate Impact Challenge (CIC) will be processed and stored. No data will be passed on to third parties. The data will be used exclusively for editorial purposes within the framework of the CIC and only within the editorial team or for evaluation within the jury and will be deleted by 31 October 2021 at the latest.

If you register for the trend newsletter, the data will be processed exclusively for sending the newsletter.

THOUGHT INDUSTRIES (LEARNING EXPERIENCE PLATFORM)

We use a Learning Experience Platform (LXP) infrastructure from Thought Industries, Inc., 6 Liberty Square #6099, Boston, MA 02109, United States ("Thought Industries") to deliver and manage our education and training courses as well as certificate creation and distribution. Thought Industries processes and stores this information on our behalf. We have entered into a "Data Processing Agreement" with Thought Industries for this purpose.

Data related to the delivery and administration of our education and training courses and the creation and distribution of certificates is processed by Thought Industries in the EU and stored on servers in Ireland. There is no transfer to countries outside the EU. For more information about the processing of data by Thought Industries, please see their privacy policy and GDPR information page.

8. Final provisions

The unlawfulness, ineffectiveness, invalidity, or unenforceability of parts of these data protection provisions and terms of use shall not affect the effectiveness and validity of the remaining provisions.