Privacy Policy

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is availableunder section “Information about the responsible party (referred to as the “controller” in the GDPR)” in thisPrivacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording duringyour website visit. This data comprises primarily technical information (e.g., web browser, operating system,or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other datamay be used to analyze your user patterns. If contracts can be concluded or initiated via the website, thetransmitted data will also be processed for contract offers, orders or other order enquiries.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archivedpersonal data at any time without having to pay a fee for such disclosures. You also have the right to demandthat your data are rectified or eradicated. If you have consented to data processing, you have the option torevoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you havethe right to log a complaint with the competent supervising agency. Please do not hesitate to contact us at any time if you have questions about this or any other data protectionrelated issues.

The provider is the Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafterreferred to as “Webflow”). When you visit our website, Webflow records various logfiles, including your IPaddress.

Webflow is a tool for the creation and hosting of websites. Webflow stores cookies or other recognitiontechnologies that are required for the depiction of the site, for the provision of certain website functions andto guarantee its security (necessary cookies).

For details, please consult the data privacy policy of Webflow: https://webflow.com/legal/eu-privacy-policy.

We use Webflow on the basis of Art.6(1)(f) GDPR. We have a legitimate interest in ensuring that our websiteis depicted as reliable as possible. If appropriate consent has been obtained, the processing is carried outexclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaningof the TDDDG. This consent can be revoked at any time.

The transfer of data to the United States is based on the standard contract clauses of the EU Commission.For details, please go to: https://webflow.com/legal/eu-privacy-policy.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is anagreement between the European Union and the US, which is intended to ensure compliance with Europeandata protection standards for data processing in the US. Every company certified under the DPF is obliged tocomply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.
gov/participant/6365.

The operators of this website and its pages take the protection of your personal data very seriously. Hence,we handle your personal data as confidential information and in compliance with the statutory dataprotection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprisesdata that can be used to personally identify you. This Data Protection Declaration explains which data wecollect as well as the purposes we use this data for. It also explains how, and for which purpose theinformation is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)may be prone to security gaps. It is not possible to completely protect data against third-party access.

The data processing controller on this website is:

Stellini Advisors GmbH
Bürgerspitalgasse 12/8
Wien, 1060, AT

Phone: +43 6645100255
E-mail: mstellini@stelliniadvisors.com

The controller is the natural person or legal entity that single-handedly or jointly with others makesdecisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mailaddresses, etc.).

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.

Whenever you use this website, a variety of personal information will be collected. Personal data comprisesdata that can be used to personally identify you. This Data Protection Declaration explains which data wecollect as well as the purposes we use this data for. It also explains how, and for which purpose theinformation is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)may be prone to security gaps. It is not possible to completely protect data against third-party access.

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR orArt. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case ofexplicit consent to the transfer of personal data to third countries, the data processing is also based on Art.49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your enddevice (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. Theconsent can be revoked at any time. If your data is required for the fulfillment of a contract or for theimplementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art.6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interestaccording to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided inthe following paragraphs of this privacy policy.

In the scope of our business activities, we cooperate with various external parties. In some cases, this alsorequires the transfer of personal data to these external parties. We only disclose personal data to externalparties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g.,disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f)GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclosepersonal data of our customers on the basis of a valid contract on data processing. In the case of jointprocessing, a joint processing agreement is concluded.

A wide range of data processing transactions are possible only subject to your express consent. You can alsorevoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness4 / 7of any data collection that occurred prior to your revocation.

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVETHE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ONGROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASEDON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA ISBASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WEWILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TOPRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THEPROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTIONPURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FORTHE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THEEXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONALDATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES(OBJECTION PURSUANT TO ART. 21(2) GDPR).

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisoryagency, in particular in the member state where they usually maintain their domicile, place of work or at theplace where the alleged violation occurred. The right to log a complaint is in effect regardless of any otheradministrative or court proceedings available as legal recourses.

You have the right to have data that we process automatically on the basis of your consent or in fulfillment ofa contract handed over to you or to a third party in a common, machine-readable format. If you shoulddemand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Within the scope of the applicable statutory provisions, you have the right to demand information aboutyour archived personal data, their source and recipients as well as the purpose of the processing of your dataat any time. You may also have a right to have your data rectified or eradicated. If you have questions aboutthis subject matter or any other questions about personal data, please do not hesitate to contact us at anytime.

You have the right to demand the imposition of restrictions as far as the processing of your personal data isconcerned. To do so, you may contact us at any time. The right to demand restriction of processing applies inthe following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually needsome time to verify this claim. During the time that this investigation is ongoing, you have the right todemand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to5 / 7demand the restriction of the processing of your data instead of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legalentitlements, you have the right to demand the restriction of the processing of your personal data insteadof its eradication.
• If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to beweighed against each other. As long as it has not been determined whose interests prevail, you have theright to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving –may be processed only subject to your consent or to claim, exercise or defend legal entitlements or toprotect the rights of other natural persons or legal entities or for important public interest reasons cited bythe European Union or a member state of the EU.

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,request) will be stored and processed by us for the purpose of processing your request. We do not pass thesedata on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of acontract or is required for the performance of pre-contractual measures. In all other cases, the data areprocessed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can berevoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke yourconsent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.