Privacy and Cookie Policy
Please note, the below information is in accordance with Article 13 GDPR. For all inquiries concerning the protection of your personal data, and the corresponding information provided below, please contact Sparring Capital Management GmbH via email at office@sparring.capital.
Welcome to https://sparring.capital, the website of Sparring Capital Management GmbH (“Sparring”). We are committed to protecting your personal data and information according to the applicable law. For this reason, your data will be used exclusively on the basis of the applicable legal provisions, in particular the National Data Protection Act (DSG), the General Data Protection Regulation (GDPR) as well as the Federal Act enacting the Telecommunications Act (TKG 2003).
The use of websites of Sparring is possible without any indication of personal data; however, if a requests certain services through our website (e.g., newsletter notifications), processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
By means of this Privacy and Cookie Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, users of our website are informed, by means of this data protection declaration, of the rights to which they are entitled.
1. Definitions
"Personal Information" refers to information that falls into one or more of the following categories: (a) information that directly identifies an individual or (b) information related to a recognizable individual, meaning someone who can be identified, whether directly or indirectly. This identification can be accomplished through the use of an identifier such as a name, an identification number, location data, an online identifier, or specific factors related to their physical, physiological, genetic, mental, economic, cultural, or social identity. Additionally, (c) it includes individually identifiable information about an online consumer that we collect through this website and maintain in a retrievable form, or (d) information that we are obligated to safeguard under applicable data privacy laws, including national, international, and supranational data protection and privacy laws, directives, regulations, and similar legal provisions.
Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;
"Processing" refers to any action or series of actions carried out on Personal Information or collections of Personal Information, whether automated or not. These actions include gathering, recording, organizing, structuring, storing, modifying, adapting, retrieving, consulting, using, transmitting through disclosure, distributing, making available, aligning, combining, blocking, limiting, erasing, or destroying.
"Sensitive Personal Information" encompasses Personal Information that discloses details such as an individual's racial or ethnic background, political affiliations, religious or philosophical convictions, or membership in a trade union. It also includes the Processing of genetic data, biometric data used for uniquely identifying an individual, information related to health, as well as data concerning an individual's sexual life or sexual orientation.
“Site” means / and all web pages hosted at that domain.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Sparring Capital Management GmbH
Stubenring 24/9
1010 Vienna, Austria
Email: office@sparring.capital
Website: https://www.sparring.capital
3. Processing of your personal information
We process personal data for the purposes of the performance of our (pre-) contractual duties (art 6 para 1 point b GDPR; e.g. in case we provide any information to you upon your request) according to our contractual relationship with you or for the purposes of our legitimate interests (e.g. operation, analysis and improvement of our website, cookies).
You have the right to object to the processing of your personal data based on our legitimate interests with effect for future processing activities (see under Section 5 “Your rights”). Depending on your interaction with the Site, the following Personal Information is processed by us for the purposes as set out in the following:
3.1 Marketing activities
On our website, you have the option to share information about yourself and your company with us. We will handle your personal data, including your name, address, and email address, to deliver alerts, updates on news and developments, expert articles, and event invitations from Sparring, provided you have indicated your interest in receiving such information.
3.2 Cookies
Our website utilizes cookies, which are small text files that your web browser downloads and stores on the device you use to visit the site, such as your desktop computer, tablet, or smartphone. Cookies serve various purposes, including recording specific user-related information like your preferences, authentication details, security settings, device-related data, and statistical information related to your interactions with the site.
During your visit to the site or when you return to it, your web browser sends these cookies, along with the information they contain, back to the servers from which they were originally obtained. Analyzing and processing this information allows us to ensure the site's functionality, enhance your online experience, and optimize the structure and content of the site. Our cookies can be categorized as follows:
Session Cookies:
These are cookies that enable our website to gather data about your activities during each browsing session when you access the site. When your device connects to our server, it is assigned a session ID, which helps our server recognize your device throughout your visit, making the site more user-friendly. These cookies are temporary and are scheduled for removal once you exit the site.
Persistent Cookies:
These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit;
First-Party Cookies:
These cookies are placed on your device by us, as the controller of your Personal Information, when you visit our website. These cookies may also encompass those associated with third-party service providers, as long as we have control over and determine the intentions and methods of processing the Personal Information recorded by these cookies. Consequently, first-party cookies might capture user-specific Personal Information that can be accessed and processed by third parties on our behalf, following our directives.
Third-Party Cookies:
These are cookies placed on your device by third parties who define the objectives and methods for processing the Personal Information collected through these cookies. When you visit our website, you have the ability to control the degree and extent of cookie usage. Specifically, you can prevent cookies from being stored on your device by configuring the settings in your web browser.
For more information on how to do so in the settings of your particular Internet browser, please see the following information:
Internet Explorer: https://privacy.microsoft.com/en-us/internet-explorer-ie11-preview-privacy-statement
Chrome: https://www.google.com/intl/en/chrome/browser/privacy/
Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy
Safari: http://www.apple.com/privacy/manage-your-privacy/
However, please be aware that this might render certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
For additional information on first-party and third-party cookies used on our Site in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services” below.
3.3. Third-Party Services
On our Site, we might or will use the following services provided by third parties:
Google Analytics
We use Google Analytics. This is a service by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google uses “Cookies”. Cookies are text files which will be stored on your computer and which enable us to analyze your use of our website applications.
The information about your use of our website (including your IP-address) generated by the Cookie will be transferred to a Google server in the USA and stored on this server. Google will use this information to analyze how you use our website and generate reports on the activities on our website for us in order to perform other services related to the use of our website and the use of the internet.
Third party service providers, including Google, will generate advertisements on websites. Third party service providers, including Google, use stored Cookies in order to generate advertisements based on the prior visits of our website by a user. Google will transfer this information to third parties, if Google is legally obligated to do so or as far as third parties process this personal data on behalf of Google.
Under no circumstances will Google connect your IP-address with other data owned by Google. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser help menu for how to do this). Please be aware that disabling cookies will affect the functionality of this websites and that you might not be able to use all functionalities of our website when disabling Cookies.
You can prevent the use of Cookies by Google by switching to the Disabling Advertisement Website by Google (http://www.google.com/privacy_ads.html). You may also deactivate the use of Cookies by third party service providers by clicking on the deactivation website by network advertising: http://www.networkadvertising.org/managing/opt_out.asp
Our website uses Google Analytics with the “anonymizeIP” extension. All IP-addresses will be anonymized, excluding any personal references.
Youtube
Our websites regularly provides content from YouTube. YouTube is an internet video portal of YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc. On YouTube, users can post videos that other users can view, rate, or comment on.
When you visit any of our sites hosting content from YouTube, your browser is automatically caused by the respective YouTube component to download the corresponding YouTube component of YouTube, giving YouTube and Google an understanding of what specific page you are visiting. This information is collected through YouTube and Google and, if you are logged in to YouTube, associated with your YouTube account. This happens regardless of whether you click on a YouTube video on our pages or not.
If you wish to prevent such information from being transmitted to YouTube and Google, you must log out of your YouTube account before visiting our website. YouTube’s privacy policy is available at https://www.google.com/intl/en/policies/privacy/.
4. Data Security and Transfer of Data
We transfer personal data to third parties such as:
Host providers: Hetzner Online GmbH, Germany
Newsletter mailing: Rocket Science Group LLC d/b/a MailChimp, USA
Contact forms: Google LLC, USA; F Stack Ltd, England;
Typeform: S.L., Spain;
We will make sure that your personal data is transferred on the basis of Standard Contractual Clauses (as of today: 2010/87/EC and/or 2004/915/EC), if the above-mentioned recipients of your personal data are seated outside CEE and if the Commission has not decided that there is an adequate level of data protection in place in the country where the recipient of your personal data is seated or otherwise in accordance with Articles 46, 47 or 49 GDPR.
Furthermore, service providers (processors) will receive your personal data from us in order to render their respective services (e.g. IT-service providers). All service providers are contractually obligated to keep your personal data confidential and may use your personal data only on our behalf and in line with our instructions. We therefore comply with the provisions of Article 32 DSGVO in order to guarantee the confidentiality and security of your personal data and take appropriate technical and organisational security measures.
Notwithstanding efforts to maintain a consistently high level of due diligence, the possibility cannot be excluded that information that you provide to us via the Internet may be viewed and used by others. Please note that we therefore accept no liability whatsoever for the disclosure of information due to errors in data transmission and/or unauthorized access by third parties not caused by us (e.g. hacker attack on email accounts or telephone, interception of faxes).
5. Your rights
Right to information
While we continue to process your Personal Information, you are entitled to receive information about the purposes of the processing, the categories of personal data involved, the source of this data, the recipients of your personal data, and the duration of its storage. Please note that your right to information may be subject to our professional duty of confidentiality.
Right to object
You have the right to object to the processing of your Personal Information based on our legitimate interests, as outlined in Article 6, Paragraph 1, Point (f) of the GDPR. You can exercise this right at any time for reasons related to your specific situation. If you object to such processing, we will stop processing your data unless our legitimate interests override your objection. If your Personal Information is being processed for direct marketing purposes, you also have the right to object at any time. In this scenario, we will promptly cease processing your Personal Information for marketing purposes.
Rectification and erasure of data
If we process inaccurate or incomplete Personal Information, you have the right to rectification of such data. If your Personal Information is processed unlawfully, you may also request us to erase your Personal Information. You may also request the erasure of your Personal Information if your data is processed unlawfully, subject to legal obligations preventing the erasure of your personal data.
Limitation of processing
In certain situations, you have the option to ask us to restrict the processing of your Personal Information.
Data portability
You are entitled to obtain the Personal Information that you have furnished to us in a format that is structured, widely recognized, and machine-readable. You also have the right to request the transfer of this data to another data controller, provided that such a transfer is technically feasible.
Complaint
You have the right to lodge a complaint with the Austrian Data Protection Authority (Österreichische Datenschutzbehörde), Wickenburggasse 8, 1080 Wien, +43 1 531 15-202525, E-Mail: dsb@dsb.gv.at if you believe that your rights to protection of your personal data have been infringed.
6. Changes to this Privacy Policy
Due to ongoing further development, this Privacy Policy will continue to be adapted. Changes will be announced on this website in due time. Therefore, you should regularly access this Privacy Policy in order to inform yourself about the current version.