Privacy policy
Mandatory information pursuant to Articles 13 and 14 of the GDPR, provided for informational purposes only
T&D Agri GmbH, Wiener Straße 64, 3100 St. Pölten, FN 561428f, St. Pölten Regional Court (hereinafter “T&D Agri”) collects, processes, and uses your personal data in accordance with applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).
This Privacy Policy is intended for customers, users, prospective customers, and visitors to the T&D Agri website and its offerings—in particular, the winewallet and the winewallet—as well as job applicants, contest participants, and visitors to T&D Agri’s online presence on social media. It describes how your personal data is handled in connection with your use of the website wine-wallet, the integrated online forms, the user account, and the services offered, the winewallet directly to winewallet shipping option through our partners, the application process, sweepstakes, and T&D Agri’s social media presence, and how it is subsequently processed and transferred.
Personal data is all data that contains details of personal or factual circumstances relating to an identified or identifiable natural person.
We collect only those personal data that are necessary for the provision, performance, and processing of T&D Agri’s services; for which there is a legal obligation to process them; for which you have given your consent; or for which T&D Agri has an overriding legitimate interest. An exception to this is the use of such data for statistical purposes, provided that the data provided have been anonymized.
For more details on the rights and entitlements of data subjects, see:
In the following sections, you will learn more about data processing:
- Section C describes the processing of personal data in connection with visits to the website.
- Section D describes the processing of personal data in connection with communications with prospective customers and the use of the forms integrated into the website for this purpose.
- Section E describes the processing of personal data in connection with the provision of services, in particular the user account and contract administration for winewallet and winewallet.
- Section F describes T&D Agri’s data collection from partners in connection with the use of the winewallet directly to winewallet shipping option.
- Section G describes the processing of personal data in the context of a job application process.
- Section H describes the processing of personal data in connection with sweepstakes.
- Section I describes the processing of personal data in connection with our online presence on social media platforms.
In the following section, you can learn more about your data security and changes to this privacy policy:
A. Rights of Data Subjects
As a data subject, you have the right at any time to obtain information about your personal data that is being processed, its origin and recipients, and the purpose of the data processing, as well as the right to rectification, data portability, objection, restriction of processing, and erasure of inaccurate or unlawfully processed data.
You have the right to withdraw your consent to the use of your personal data at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Furthermore, the withdrawal of consent has no influence on data processing that is based on a different legal basis.
Pursuant to Article 21 of the GDPR, you have the right to object to the processing of your personal data if your personal data is being processed on the basis of legitimate interests pursuant to Article 6(1)(f) of the GDPR and there are reasons arising from your particular situation (paragraph 1), or if your personal data is being processed for direct marketing purposes (paragraph 2).
Your requests for access, erasure, restriction of processing, rectification, objection, and/or data portability may be sent to the T&D Agri address listed in Section B of this Privacy Policy.
If you believe that T&D Agri’s processing of your personal data violates applicable data protection laws or that your data protection rights have been infringed upon in any other way, you may file a complaint with the competent supervisory authorities. In Austria, the competent authority for this is the Data Protection Authority (Barichgasse 40-42, 1030 Vienna, Phone: +43 1 52 152-0, Email: dsb@dsb.gv.at).
B. Our Contact Information
The protection of your data is particularly important to us. You can contact us at any time using the contact details below if you have any questions or wish to exercise your rights:
T&D Agri GmbH
64 Wiener Straße
3100 St. Pölten
Email: [wine-wallet]
Phone number [05025921150]
C. Data Processing on the Website
- Categories of Personal Data Collected
Every time the website is accessed, the system automatically collects data and information from the visitor's computer system. The following data is collected:
- Full IP address of the requesting computer;
- Date and time of access;
- Websites from which the user's system accesses our website;
- Name of the requested file;
- Access status (file transferred, file not found, etc.);
- Web browser and operating system used;
- Language settings;
- Referrer URL;
- Internet service provider;
- Amount of data transferred;
- Purposes of Processing
The processing of personal data on the public website (i.e., outside the user account; see Section E) is limited to the data necessary to provide a fully functional website and user-friendly content and services.
In particular, T&D Agri therefore collects personal data on its website,
- for internal administrative purposes (e.g., ensuring the stability and operational reliability of the system);
- to optimize the website, online advertising strategies, and the portal,
- Legal Basis
T&D Agri processes personal data in connection with the website on the following grounds pursuant to Article 6(1) of the GDPR:
- The use of online identifiers (e.g., cookie IDs), IP addresses (which may be truncated), device and browser data, usage events, and contact/newsletter data (email address, first name, last name) for audience measurement, statistics, and marketing, as well as for sending newsletters, is based on your consent. You may revoke your consent at any time with future effect. You can do so via the unsubscribe link in the newsletter or by sending us a message. This is done in accordance with your consent (Article 6(1)(a) of the GDPR).
- The use of registration and account data in the backend (e.g., name, email, login credentials, address), communication content via contact forms directly related to services or offers, and, if applicable, other data necessary for use (number of bottles, etc.)] is necessary for the provision and administration of the user account/backend access and the processing of contract-related inquiries in order to fulfill the contract regarding the use of the T&D Agri website and the use of the services offered thereon, or to carry out related pre-contractual measures (Article 6(1)(b) of the GDPR).
- The use of server access data (IP address, date/time, URL, referrer, user agent, language, status code, amount of data transferred, and technically necessary cookies/session IDs] is necessary to protect the legitimate interests of T&D Agri, namely ensuring the stability and operational security of the system, as well as preventing and tracking unauthorized access or fraud attempts (in particular, fraud and bot protection for Wine Wallet), improving user-friendliness, and ensuring logging and traceability in the event of security-related incidents. (Art. 6(1)(f) GDPR).
You have the right at any time to withdraw the consent you have given for the use of your personal data as described in the first bullet point. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent has no effect on data processing based on another legal basis.
You are under no obligation to provide us with the personal data we request from you when you use the website. However, you will not be able to use the website if you do not provide your personal data. If, in certain cases, providing your data is required by law, we will notify you separately.
- Retention period
We will store your personal data for as long as necessary to fulfill the purpose of the data processing. In addition, data will be stored only to the extent that there is a corresponding legal obligation or pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data that we process in connection with your visit to the T&D Agri website (for informational purposes only) is stored until you close your browser session.
- Data that we collect through the use of cookies to improve the presentation and functionality of our website is deleted (depending on the type of cookie) either when you close your browser session or after a period of 14–30 days. For more details, please refer to Section 8 (Cookies) or the T&D Agri Cookie Policy.
Data is stored for data security reasons—in particular to defend against attempts to attack the web server—as well as to ensure the stability and operational reliability of the system.
- Disclosure of Data to Third Parties
In order to achieve the processing purposes we have specified, it may sometimes be necessary for us to disclose your data to specific recipients.
Further down in this text, you will find a list of controllers and processors to whom we may, on a case-by-case basis, transfer, provide, or otherwise make personal data available. Where it is not possible to name specific recipients here, the GDPR allows us to specify categories of recipients.
In some cases, we intend to transfer personal data in this context to data controllers and/or data processors that are not based within the European Economic Area. In the following, we therefore provide additional information about which recipients are based in a third country and the legal basis on which we transfer data to these recipients.
Where applicable, we transfer personal data based on an adequacy decision by the European Commission. If no such decision exists, we transfer personal data only in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient, or based on an exception expressly provided for by law. A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding recipient categories: If the table below lists only categories of recipients and the table does not expressly state otherwise, we generally do not intend to transfer personal data to data controllers and/or data processors that are not established within the European Economic Area, unless you establish such a connection to a third country in a specific case. If, in exceptional cases, you establish a connection to a third country (e.g., because we must enforce an outstanding claim against you in a third country or because you have requested that we ship wines to you in a third country), we will transfer personal data, where applicable, based on an adequacy decision by the European Commission. If no such decision exists, we will transfer personal data exclusively in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient or on the basis of an exception expressly provided for by law (e.g., your consent). A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding data transfers to the U.S.: In particular, the website uses standard third-party cookies and services provided by companies based in the U.S., which are described in more detail below. These are used with your consent, and personal data may then be transferred, in particular, to the U.S. servers of the respective companies. The U.S. is not a safe third country and does not maintain an adequate level of data protection as defined by EU data protection law. Due to the legal situation there, recipients in the U.S. may be required to disclose personal data to law enforcement agencies. As a data subject, you have no recourse against this. It therefore cannot be ruled out that U.S. authorities and security agencies may process personal data for surveillance purposes, over which T&D Agri has no further control.
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country |
Meta Pixel | Meta Platforms Ireland (EU) & Meta Platforms, Inc. (U.S.) | EU-U.S. Data Privacy Framework (DPF) = Art. 45 (Meta is DPF-certified) |
Google Tag Manager | Google Ireland (EU) & Google LLC (U.S.) | DPF/Art. 45 (Certified by Google LLC) |
Google Analytics (GA4) | Google Ireland (EU) & Google LLC (U.S.) | DPF/Art. 45; browser opt-out also available |
HubSpot (forms, newsletters, CRM, landing pages) | HubSpot Ireland (EU) | If U.S. hosting/subprocessors: DPF/Art. 45 (HubSpot Inc. certified) |
"Sign in/register with Google" (Google Sign-In/OAuth) | Google Ireland (EU) & Google LLC (U.S.) | DPF/Art. 45 |
World4You Internet Services, LLC | Austria (EEA) | Server locations in Austria/the EU; data processing on behalf of a client pursuant to Article 28 of the GDPR |
- Use of Web Analytics, Remarketing, Retargeting, and Statistics Tools
T&D Agri uses various tools for web analytics, remarketing, retargeting, and the compilation of statistics in order to optimize its online presence and website in terms of user-friendliness and to provide tailored, useful information about T&D Agri’s services. This process involves the use of cookies (see Section 8), the assignment of a random user ID, and the collection and analysis of various types of data. This includes, for example, the number of website visitors, abandonment rates during the registration process, conversion rates, duration of visits, average page load time, and the origin of visitors. The analyses are based on anonymized data sets. No personal data is evaluated. This data is not combined with any sources of personal data.
T&D Agri analyzes website usage using the following web analytics and statistics tools:
- Google Analytics
- HubSpot Analytics
- Sourcebuster JS
T&D Agri analyzes website usage using the following remarketing and retargeting tools:
- Google Ads
- HubSpot Analytics
- Facebook/Meta Pixel
- Google Adsense
T&D Agri GmbH uses other online services that are relevant to cookies and data transfer but do not perform analytics in the strict sense:
- Google reCAPTCHA (spam protection for forms)
- Google Fonts (Web Fonts)
- WordPress/Elementor (functional cookies)
- PayPal cookies (payment service, confirmed via the cookie list)
In the detailed descriptions, you can see how these tools work and what specific benefits they offer.
- Google Analytics:
This T&D Agri website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies (see Section 8).
The information generated by the cookie regarding your use of this T&D Agri website (including your IP address and the URLs of the web pages you visit) is transmitted to a Google server in the United States and stored there. T&D Agri does not store any of your data collected in connection with Google Analytics.
This website uses the IP anonymization feature provided by Google Analytics. Your IP address is therefore truncated/anonymized by Google as soon as Google receives it. On behalf of T&D Agri, Google will use this information to evaluate your use of the website, to compile reports on website activity for T&D Agri, and to provide other services to T&D Agri related to website and internet usage. Google may also transfer this information to third parties where required by law or where such third parties process the data on Google’s behalf. Google will under no circumstances associate your IP address with any other data held by Google.
You can prevent cookies from being stored by adjusting your browser settings accordingly. However, please note that in this case, you may not be able to use all of this website's features to their full extent.
You can also prevent Google from collecting your data in connection with Google Analytics at any time, with future effect, by using the opt-out add-ons provided (https://tools.google.com/dlpage/gaoptout?hl=de).
You can withdraw your consent at any time in the cookie settings on this website. You can also prevent Google Analytics from collecting data by
For more information about Google's Terms of Service and Privacy Policy, please visithttp://www.google.com/analytics/terms/de.htmlorhttps://www.google.de/intl/de/policies/.
The United States is not a safe third country and does not have an adequate level of data protection as defined by EU data protection law. See also point 5.
- Google Tag Manager:
This T&D Agri website uses Google Tag Manager, a tag management service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Tag Manager itself does not set cookies or store personal data; however, it enables the triggering of other tags and scripts, which in turn may collect data (see the respective sections below, e.g., Google Analytics/Google Ads).
When the Tag Manager is running, technical requests are sent to Google (e.g., your IP address, user agent, and the URL you visited) in order to deliver the tags. [T&D Agri does not store any of your data collected in connection with Google Tag Manager.]
Non-essential tags (e.g., analytics/marketing) are only activated with your consent (see Section 8). You can change your consent at any time, effective for the future, via the consent banner.
For more information, please see Google’s Terms of Service and Privacy Policy at https://www.google.com/intl/de/tagmanager/use-policy.html and at https://policies.google.com/privacy. The United States is not a safe third country and does not provide an adequate level of data protection within the meaning of EU data protection law. See also Section 5.
- Google Ads:
This T&D Agri website uses Google Ads, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), including conversion tracking and remarketing. Google Ads uses cookies (see Section 8).
The information generated by the cookie regarding your use of this website (e.g., cookie ID, pages visited, interactions, advertising ID/click ID (e.g., “gclid”), browser/device information, [IP address (truncated)]) is transmitted to Google’s servers, including those in the United States, and stored there. [T&D Agri does not store any of your data collected in connection with Google Ads.]
On behalf of T&D Agri, Google uses this information to measure conversions (e.g., form submissions) and—if remarketing is enabled—to serve usage-based ads on Google services and among its partners. Google may transfer this information to third parties if required by law or if such third parties process this data on Google’s behalf. Google will not combine your data with other data held by Google that you have provided directly to Google.
The use of Google Ads (especially remarketing) is based solely on your consent. You can prevent cookies from being stored in your browser; however, this may mean that not all features of the website will be available to you. In addition, you can disable personalized ads from Google in your ad settings (https://adssettings.google.com/) and opt out via the Network Advertising Initiative’s opt-out page (http://www.networkadvertising.org/choices/). [You can also prevent the collection of your data on this website by revoking your consent in the consent banner.]
For more information, visit https://policies.google.com/technologies/ads and https://policies.google.com/privacy. The United States is not a safe third country; see point 5.
- Hupspot Analytics:
This T&D Agri website uses the analytics and marketing features of HubSpot (HubSpot Ireland Limited, 1 Sir John Rogerson’s Quay, Dublin 2, Ireland; HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA). HubSpot uses cookies (see Section 8), including __hstc, hubspotutk, __hssc, __hssrc, and messagesUtk, to track page views, sessions, timestamps, referrers, device/browser data, and interactions with forms and newsletters.
The information generated by cookies about your use of this website is transmitted to HubSpot’s servers and stored there, in some cases in the United States. [T&D Agri does not store any of your data collected in connection with HubSpot Analytics.] Note: When you submit a form (e.g., contact/newsletter), HubSpot may link the previously set cookie (e.g., hubspotutk) to the contact information you provided (e.g., email, name) in order to associate interactions with your profile in the CRM.
On behalf of T&D Agri, HubSpot uses this information to analyze website usage, generate reports, and support contact and newsletter communications (including double opt-in and performance tracking, such as opens and clicks). HubSpot may share the data with service providers if required by law or if such service providers process the data on HubSpot’s behalf.
The use of HubSpot cookies for analytics and marketing purposes is based solely on your consent. You can prevent cookies from being stored by adjusting your browser settings accordingly; you can also withdraw your consent at any time via the consent banner. [For newsletters, you can also withdraw your consent at any time by clicking the unsubscribe link.]
For more information about HubSpot’s Terms of Service and Privacy Policy, visit https://legal.hubspot.com/de/privacy-policy and https://legal.hubspot.com/de/cookie-policy. The United States is not a safe third country; see Section 5.
- Facebook Pixel
The T&D Agri website uses “Facebook Pixel” from Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
T&D Agri can therefore track your activities after you click on a Facebook ad that redirects you to our website. This is done to track the effectiveness of Facebook advertising for statistical and market research purposes and may be used to optimize future ads for you.
All data collected remains anonymous to T&D Agri, so we cannot use it to identify any user. However, Facebook stores and processes data that allows it to link to your user profile and enables Facebook to use your data for advertising purposes in accordance with the Facebook Privacy Policy (https://de-de.facebook.com/policy.php). This allows Facebook and its partners to serve ads both on and off Facebook.
A cookie may also be stored on your computer for these purposes. Please see Section 8 (Cookies) or the T&D Agri Cookie Policy for more information.
- LinkedIn Insight Tag:
This T&D Agri website may use the “LinkedIn Insight Tag” provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”). The Insight Tag uses cookies (see Section 8) to measure conversions, analyze website visits, and create audiences for ads.
Categories of data: LinkedIn cookie ID, IP address (truncated), device/browser data, page views, referrer, timestamps, event data (e.g., form submission/click).
Purposes: Audience measurement, conversion tracking, (re)targeting on LinkedIn services.
Transmission to: LinkedIn Ireland Unlimited Company; if applicable, LinkedIn Corporation, USA.
Legal basis: Your consent (Art. 6(1)(a) GDPR).
Objection/Opt-out: You can disable personalized advertising in the advertising settings on LinkedIn (https://www.linkedin.com/psettings/advertising) and withdraw your consent via the consent banner.
Third Countries: When data is transferred to the U.S., this is done—where available—based on the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or appropriate safeguards (Art. 46 GDPR, Standard Contractual Clauses). For details, see the list of recipients.
- Google AdSense
This T&D Agri website uses Google AdSense, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), to display advertisements. AdSense uses cookies (see Section 8) and may process advertising IDs/click IDs (e.g., “gclid”).
Categories of data: Cookie ID (e.g., _gcl_au), page views, interactions, approximate location data, device/browser information, and, if applicable, click ID.
Purposes: Display of contextual and (with consent) personalized ads, as well as measurement of reach and conversions.
Transfer to: Google Ireland Limited; and, if applicable, Google LLC, USA.
Legal basis: Your consent (Art. 6(1)(a) GDPR).
Objection/Opt-out: https://adssettings.google.com/ as well as revocation via the consent banner.
Third countries: Transfers to the U.S.—where necessary—pursuant to Art. 45 GDPR (DPF) or Art. 46 GDPR (SCC).
- Google reCAPTCHA
This website uses Google reCAPTCHA (Google Ireland Limited) to protect forms from spam and abuse. reCAPTCHA analyzes user behavior to detect automated access.
Categories of data: Mouse/keyboard interactions, device/browser data, referrer URL, IP address, timestamp, and, if applicable, Google cookie IDs.
Purposes: Spam/bot detection, form security.
Transfer to: Google Ireland Limited; and, if applicable, Google LLC, USA.
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) in securing our online forms; to the extent that cookies are set or read, consent (Art. 6(1)(a) GDPR / § 165 TKG).
Third countries: See above (DPF/SCC).
- Sourcebuster JS
We use Sourcebuster JS for attribution analysis to track the origin of visits (campaign/medium/source) and conversion paths.
Data categories: Campaign/referrer information (e.g., UTM parameters), session/timestamps, browser/device information, pseudonymous IDs (cookies such as sbjs_*).
Purposes: Statistical analysis of traffic sources and conversion paths (without identification).
Transfer to: None (first-party use); data is not shared with third parties.
Legal basis: Your consent (Art. 6(1)(a) GDPR) for statistical cookies.
- Content Management Systems:
T&D Agri uses third-party content management (CMS) services to integrate their capabilities for creating, editing, organizing, presenting, and delivering digital content.
T&D Agri uses the following CMS systems:
- WordPress
- HubSpot
- Elementor
In the detailed descriptions, you can see how these services work and what specific benefits they offer.
- WordPress:
This T&D Agri website uses WordPress as its content management system.
Categories of data: technically necessary cookies and local storage (e.g., wordpress_logged_in_*, wp-settings-*), IP address/HTTP data when pages are accessed, and, if applicable, login/session information for user accounts.
Purposes: Creation, editing, and delivery of content; user management; sessions; performance.
Transfer to: No regular transfer to third parties; hosted by World4You in the EU (see list of recipients).
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) in the operation and security of the website; additionally, for login/accounts, a contract (Art. 6(1)(b)).
- HubSpot:
In addition to Analytics, T&D Agri also uses HubSpot for forms, newsletters, landing pages, and CRM.
Data categories: Form data (e.g., name, email), usage/interaction data, cookies such as hubspotutk, __hstc, __hssc, __hssrc, message/chat IDs (messagesUtk).
Purposes: Lead management, newsletters (including double opt-in, opens/clicks), campaign analysis; provision of landing pages.
Transfer to: HubSpot Ireland Ltd.; if applicable, HubSpot Inc., USA (sub-processors/hosting).
Legal basis: Consent (Art. 6(1)(a)) for tracking/newsletters; contract (Art. 6(1)(b)) for processing specific inquiries; legitimate interest (Art. 6(1)(f)) in efficient communication.
Third countries: DPF/SCC depending on the circumstances.
- Elementor:
This website uses Elementor (a page builder plugin for WordPress) to design and manage page content.
Data categories: functional cookies/local storage entries (e.g., Elementor) for storing page settings; IP/HTTP data upon access.
Purposes: display/rendering of content, stability/performance.
Transfer to: No regular transfer to third parties by the plugin itself.
Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) in the operation/design of the website; cookies only to the extent technically necessary.
- Cookies
The T&D Agri website uses "cookies" to make the site more user-friendly, effective, and secure. For more details, please see the T&D Agri Cookie Policy.
- Google Fonts
Data categories: IP address, requested font URL, HTTP headers (including User-Agent), referrer URL, timestamp.Purpose: Consistent font rendering; performance optimization.
Transferred to: Google Ireland Limited; or, if applicable, Google LLC, USA (when accessed via Google CDN). You can find more information about how Google Fonts uses data here: https://policies.google.com/technologies/cookies?hl=de
Legal basis: Your consent under Article 6(1)(a) of the GDPR, as well as the website operator’s legitimate interest in optimizing the website and advertising under Article 6(1)(f) of the GDPR.
- Server Log Files
To optimize the T&D Agri website in terms of system performance, user-friendliness, and the provision of useful information about our services, the website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This includes
- Your Internet Protocol address (IP address),
- Your browser and language settings,
- Your operating system,
- Your referrer URL,
- Hostname of the connecting computer
- Your Internet service provider and
- Date and time of the server request.
This data will not be combined with [other] sources of personal data. Storage is temporary and is carried out solely to defend against hackers, balancing T&D Agri’s interest in protection with your right to privacy. T&D Agri reserves the right to review this data at a later date if concrete evidence of unlawful use comes to light.
- Integration with Services / Platforms / Social Networks
The T&D Agri website uses third-party services to survey website users.
T&D Agri uses the following services:
- HeyFlow
In the detailed descriptions, you can see how these services work and what specific benefits they offer.
- HeyFlow:
T&D Agri does not use Heyflow (Heyflow GmbH, Jungfernstieg 49, 20354 Hamburg, Germany) as an integrated service on this website. Instead, our META ads (Facebook/Instagram) link to an external Heyflow page where interested parties can—voluntarily—enter their information to receive details about our services (e.g., “Storage Information” or “General Information First”). Data collection therefore takes place outside of our website; Heyflow does not set any cookies or tags on this website.
Categories of data: the information you enter in the form (e.g., name, email address, phone number, selected information preference), the timestamp of submission; and, if applicable, campaign parameters from the ad (e.g., UTM tags/click ID), to the extent that they are transmitted by you or your browser.
Purposes: Receiving and processing your inquiry, contacting you based on your selection, providing the requested information, lead management, and documenting your consent/inquiry.
Legal Basis:
- Art. 6(1)(b) of the GDPR (contract/precontractual measures), when you request contact or information and we contact you in this regard either once or in connection with the specific request.
- Art. 6(1)(a) of the GDPR (Consent), if you consent to receiving further marketing communications (e.g., newsletters, periodic updates); this consent may be revoked with future effect.
- Art. 6(1)(f) of the GDPR (legitimate interest) for spam and abuse prevention, proof of proper consent, and internal lead attribution to the minimum extent necessary.
Recipient/Order Processing:
- Heyflow GmbH as a data processor (hosting/technical support for the external form page; according to the provider, hosting is located in the EU).
- After submission, the form data is automatically transmitted to our CRM “HubSpot” (HubSpot Ireland Ltd.; or, where applicable, HubSpot Inc., USA, as a group company or sub-processor) and stored there for the purpose of processing the inquiry. Any transfers to third countries—where applicable—are carried out on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or the Standard Contractual Clauses (Art. 46 GDPR); for details, see the list of recipients/basis for transfers to third countries.
Retention Period: We store your inquiry/lead data for as long as necessary to process your inquiry and any follow-up communication; we then delete or anonymize it, unless required by statutory retention obligations (e.g., under the Austrian Commercial Code (UGB) or the Austrian Federal Tax Code (BAO)). Leads for which there is no further interest are regularly deleted after [e.g., 12 months].
Voluntary Provision/Withdrawal: Providing your data is voluntary; however, without it, we cannot contact you. You may withdraw your consent at any time (e.g., by email to the address listed in the legal notice or via unsubscribe links in emails).
Note: Since Heyflow is not integrated into our website, you cannot use the cookie settings on this website for that purpose. For information about any cookies or technologies used on the external Heyflow site, please refer to Heyflow’s privacy policy on that site.
- Translation Tools
The T&D Agri website uses third-party translation services to translate the website's content so that users can view it in their preferred language:
T&D Agri uses the following payment providers:
- Weglot
In the detailed descriptions, you can see how these services work and what specific benefits they offer.
- Weglot:
This T&D Agri website uses Weglot (Weglot SAS, 7 Cité Paradis, 75010 Paris, France) to translate the website content and display it in the language selected by the user. When the website is accessed, Weglot loads components to translate content and display a language selector. In doing so, necessary browser/HTTP data is processed; Weglot also sets functional cookies for language selection and translation performance (see Cookie Policy).
Data categories: IP address, accessed URL, HTTP headers (including User-Agent/Referrer), timestamp; function-related storage such as wg-translations (Local Storage), wg-slugs (Local Storage), and the WG_CHOOSE_ORIGINAL cookie (remembers original language / language selection). These entries are used for caching/routing and to display the selected language. Weglot Developer Documentation
Purposes: Language switching, delivery of translated content, performance (caching of translations/URL slugs).
Transmission to: Weglot SAS; according to the provider, data is hosted in the EU. Weglot+1
Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in a multilingual, user-friendly presentation; to the extent that cookies/local storage are used that are not technically necessary, consent (Art. 6(1)(a) GDPR / ePrivacy).
Withdrawal/Opt-out: You can control the storage and reading of non-essential cookies and local storage entries via the cookie settings and withdraw your consent at any time with future effect.
Third Countries: Weglot is an EU-based provider; should a transfer to a third country occur in exceptional cases via sub-processors or CDNs, it will take place in accordance with the legal bases specified in our list of recipients (DPF/Art. 45 GDPR or SCC/Art. 46 GDPR).
- Links to Other Websites
The T&D Agri website may contain links to other websites. T&D Agri has no control over those websites’ compliance with data protection regulations; therefore, this Privacy Policy does not apply to such websites.
D. Data Processing in Connection with Communication with Prospective Customers and the Forms Integrated on the Website for This Purpose
In the public section of the website, T&D Agri provides online forms for requesting information about our services and contacting us. The data entered in the forms is transmitted using encryption (HTTPS).
Purposes of processing: Processing your inquiry (follow-up questions, information provided by phone or in writing), preparing for a consultation, and—if desired—sending non-binding quotes for winewalletsubscriptions/licenses or other services offered by T&D Agri.
Linking/CRM: When you use the forms, a contact is created in our HubSpot CRM. HubSpot may associate an existing pseudonymous website identifier (e.g., the "hubspotutk" cookie) with your contact to track interactions with our website and communications.
You are under no obligation to provide us with the personal data we request via the forms available on the website. However, you will not be able to use the services offered through these forms (newsletter, consultation, free inquiries, etc.) if you do not provide your personal data. If providing your data is required by law in certain cases, we will notify you separately.
We will store the personal data you enter into the online forms for as long as necessary to fulfill the purpose of the data processing. In addition, data will only be stored to the extent that there is a corresponding legal obligation or if there are pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data we have received in connection with your requests for consultation appointments and free inquiries will be stored for a period of 7 years, to the extent that such data is subject to statutory retention requirements (e.g., § 212 UGB or § 132 BAO).
- Data we have received in connection with your newsletter subscription will generally be stored for as long as you have not revoked the consent you provided for this purpose.
The following online forms are available on the website:
- D.1. Form for Free Inquiries
- Categories of Personal Data Collected
The form for free inquiries requests the following personal information:
- First name
- Surname
- E-mail address
- Phone number
- Private Message
- Number of wine bottles that could potentially be stored
- Pickup Location
- Purposes of Processing
The personal data collected via the free inquiry form is used exclusively to contact you by phone or in writing regarding T&D Agri’s services, as well as to prepare for any phone calls, to send you non-binding offers for winewallet and winewallet or other T&D Agri services, or to address your specific inquiry.
- Legal Basis
T&D Agri processes the personal data collected through the free inquiry form on the following legal bases in accordance with Article 6(1) of the GDPR:
- The use of the data specified in Section 1 is necessary for taking advantage of the offer to receive free answers to questions and non-binding quotes, or for carrying out precontractual measures in connection with the conclusion of a winewallet or a winewallet license (Article 6(1)(b) of the GDPR).
- D.2. Newsletter
- Categories of Personal Data Collected
The newsletter sign-up form requests the following personal information:
- First name
- Surname
- E-mail address
- Purposes of Processing
The personal data collected through the newsletter sign-up form is processed solely for the purpose of providing the newsletter and special promotional offers.
- Legal Basis
T&D Agri processes the personal data collected through the newsletter form on the following grounds, in accordance with Article 6(1) of the GDPR:
- The data referred to in point 1 is used in accordance with your consent (Article 6(1)(a) of the GDPR).
You have the right to withdraw your consent to the use of your personal data at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent does not affect data processing based on another legal basis.
- D.3. Consultation Form:
- Categories of Personal Data Collected
The form for scheduling a consultation requests the following personal information:
- First name
- Surname
- E-mail address
- Phone number
- Preferred appointment time
- Number of wine bottles that could potentially be stored
- Purposes of Processing
The personal data collected in the form for scheduling a consultation is processed solely for the purpose of contacting you to arrange and prepare for the consultation, and to address the concerns you have raised.
- Legal Basis
T&D Agri processes the personal data collected through the form for scheduling a consultation on the following legal bases in accordance with Article 6(1) of the GDPR:
- The use of the data specified in Section 1 is necessary for you to participate in the consultation or for the implementation of pre-contractual measures in connection with the conclusion of a winewallet or a winewallet(Article 6(1)(b) of the GDPR).
E. Data Processing Through the User Account
T&D Agri provides a separate section of the website exclusively for customers who have either purchased a winewallet or a winewallet. This section of the website is accessible only after entering an email address and a designated password (login) (user account). In addition to the general data processing on the website (see Sections C and D), the following applies to user accounts:
- Categories of Personal Data Collected
T&D Agri processes the following categories of personal data in connection with the user account:
- Name
- E-mail address
- Country of residence
- Date of Birth and Age
- Gender
- Address
- Delivery address
- User account data, including stored wines; data on transfers of wine bottles to other users; data on wines that are not stored but have been digitized
- Content and recipients of messages and notifications sent via the portal
- User input in the system, IP address, name and version of the web browser, and the time the user account was accessed
- Terms and Conditions for the Delivery and Storage of Wines (including details regarding the place of delivery or service, packaging, etc.)
- Payment Method
- Bank Account Information
- Credit card number and credit card company
- Insurance and Related Financial Data
- Tax Liability and Tax Calculation Data
- Website (URL) that you visited before accessing your user account
- Information that you provide to us by registering for a user account and filling out forms to purchase winewallet and winewallet.
- Purposes of Processing
T&D Agri processes your data for the following purposes:
- Management of the business relationship (user account administration, registration process, use of the website, purchase of winewallet and winewallet, and related processing)
- Provision of services on the website,
- Provisioning of winewallet services,
- Storing and retrieving wine bottles,
- Transfer and acceptance of wine bottles,
- Wine Cellar Illustration,
- Calculation of applicable costs and taxes,
- Age verification for compliance with legal dispensing restrictions,
- Sending promotional and marketing information about T&D Agri's services,
- Optimization of the website, online advertising strategies and the portal,
- Managing customer relationships, including maintaining contact and communicating with customers, as well as analyzing customer needs and how our portal and services are used;
- Management of site visits;
- Analysis and forecasting of customer demand;
- Organizing events;
- Conducting customer satisfaction surveys;
- Providing information about our services and events;
- Conducting Surveys
- Conducting direct marketing and advertising through electronic and non-electronic channels.
- Legal Basis
T&D Agri processes this personal data on the following legal basis:
Contract/Pre-contractual Measures (Art. 6(1)(b) GDPR): Provision and management of the user account; conclusion and processing of subscriptions and licenses; execution of data imports, exports, and transfers; billing.
Legal obligation (Art. 6(1)(c) GDPR): in particular, age verification/protection of minors, retention requirements under tax and commercial law (e.g., BAO/UGB), and, where applicable, obligations to provide information or file reports with authorities.
Legitimate interests (Art. 6(1)(f) GDPR): Operation, stability, and security of the portal; prevention of fraud and misuse; assertion and defense of legal claims; internal organization and process documentation; the processing is foreseeable and limited to what is necessary.
Legitimate interest following submission of contact forms for marketing purposes (Art. 6(1)(a) GDPR): for newsletters/regular marketing emails, optional surveys, or additional analytics/marketing features, to the extent that they are not necessary for the performance of a contract. You may revoke your consent at any time with future effect; the lawfulness of processing prior to revocation remains unaffected.
You have the right to withdraw your consent to the use of your personal data at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent does not affect data processing based on another legal basis.
You are under no obligation to provide us with the personal data we request. However, if you do not provide your personal data, you will not be able to use all the features of your user account, nor will you be able to purchase winewallet or winewallet. In addition, business processes may be delayed or become impossible, and you may be unable to participate in our events if you do not provide your personal data. If providing your data is required by law in certain cases, we will notify you separately.
- Disclosure of Data to Third Parties
In order to achieve the processing purposes we have specified, it may sometimes be necessary for us to disclose your data to specific recipients.
Further down in this text, you will find a list of controllers and processors to whom we may, on a case-by-case basis, transfer, provide, or otherwise make personal data available. Where it is not possible to name specific recipients here, the GDPR allows us to specify categories of recipients.
In some cases, we intend to transfer personal data in this context to data controllers and/or data processors that are not based within the European Economic Area. In the following, we therefore provide you with additional information, where applicable, regarding which recipients are based in a third country and the legal basis on which we transfer data to these recipients.
Where applicable, we transfer personal data based on an adequacy decision by the European Commission. If no such decision exists, we transfer personal data only in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient, or based on an exception expressly provided for by law. A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding recipient categories: If the table below lists only categories of recipients and the table does not expressly state otherwise, we generally do not intend to transfer personal data to data controllers and/or data processors that are not established within the European Economic Area, unless you establish such a connection to a third country in a specific case. If, in exceptional cases, you establish a connection to a third country (e.g., because we must enforce an outstanding claim against you in a third country or because you have requested that we ship wines to a third country), we will transfer personal data, where applicable, based on an adequacy decision by the European Commission. If no such decision exists, we will transfer personal data exclusively in compliance with appropriate safeguards that ensure an adequate level of data protection at the recipient’s end or on the basis of an exception expressly provided for by law (e.g., your consent). A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding data transfers to the U.S.: In particular, the website—including the user account— uses standard third-party cookies and services provided by companies based in the U.S. These are used with your consent, and personal data may then be transferred to the U.S. servers of the respective companies. The U.S. is not a safe third country and does not provide an adequate level of data protection as defined by EU data protection law. Due to the legal situation in the U.S., recipients there may be required to disclose personal data to law enforcement agencies. As a data subject, you have no means of challenging this. It therefore cannot be ruled out that U.S. authorities and security agencies may process personal data for surveillance purposes, over which T&D Agri has no further control.
- General Recipients
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country | ||||
World4You Internet Services GmbH (Hosting/Server Logs, Email/SMTP) |
|
| ||||
IT service provider | EEA (AT) | not required | ||||
Legal Representative | EEA (AT) | not required | ||||
Banks and Credit Institutions / Service Providers for Payment Processing | EEA (AT) | not required | ||||
Certified Public Accountant | EEA (AT) | not required | ||||
Courts and Administrative Authorities | EEA (AT) | not required | ||||
Tax Authorities | EEA (AT) | not required | ||||
Debt Collection Agencies | EEA (AT) | not required | ||||
Contractual and business partners who are involved in or are expected to be involved in our services | EEA (AT) | not required | ||||
Insurance | EEA (AT) | not required | ||||
Companies that are part of our group | EEA (AT) | not required |
- Shipping service provider
For the purpose of storing and retrieving wine bottles as part of the winewallet, personal data [name, address, phone number, and email address] is transmitted to shipping service providers; in cases where you directly engage the shipping service providers, data processing takes place directly between you and the shipping service provider.
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country | ||||||
|
|
| ||||||
|
|
| ||||||
GO! Express & Logistics | EEA (AT) | not required |
- Warehouse Operator
For the purpose of storing wine bottles as part of the winewallet, personal data [name, address, information about the wine being stored, and phone number and email address] is transmitted to storage facility operators.
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country |
Wein-Lagerlogistik GmbH (FN 585881 s) in Parndorf | EEA | not required |
- E-Commerce-System:
T&D Agri uses third-party service offerings for e-commerce systems within the user account to integrate their services for the purchase of winewallet and winewallet.
T&D Agri uses the following e-commerce systems:
- WooCommerce
In the detailed descriptions, you can see how these services work and what specific benefits they offer.
- WooCommerce:
This website uses WooCommerce (a plugin from Automattic/WooCommerce, part of the WordPress ecosystem) to process orders, subscriptions, and licenses in the user account.
Categories of Data: Customer and contact information (name, billing/shipping address, email, phone number), account/login information, order/contract information (products, amounts, terms), status and history information (payment status, cancellations, credit notes), technical logs (timestamps, IP address/browser when using the account), optional coupons/discounts.
Purposes: Management of shopping cart/checkout, conclusion and fulfillment of contracts (subscriptions/licenses), invoicing, customer communication, fraud prevention/IT security, and for record-keeping and documentation purposes.
Legal Basis: Art. 6(1)(b) GDPR (contract/pre-contractual steps), (f) (operational necessity/IT security), (c) (legal retention requirements, etc.).
Recipients/Hosting: Operation within our WordPress system at World4You (EEA); integration of external payment providers is handled separately (see Section 6).
Retention period: Contract/billing data in accordance with legal obligations (typically 7 years); account/usage logs for security and evidentiary purposes (e.g., 14–30 days); all other data is retained until the purpose for which it was collected no longer applies.
- Payment Providers:
T&D Agri uses third-party payment service providers within the user account to integrate their services for processing payments for winewallet and winewallet. However, T&D Agri does not transfer any personal data to these providers; instead, data processing takes place directly between you and the third-party provider.
T&D Agri uses the following payment providers:
- PayPal
- Stripe
- Auxilia
In the detailed descriptions, you can see how these services work and what specific benefits they offer.
- PayPal:
Data Controller/Service: PayPal Europe S.à r.l. et Cie, S.C.A. (Luxembourg); Group company PayPal Inc. (USA).
Categories of data: Identification and contact information (name, email), billing/shipping address (if required), payment/transaction data (amount, currency, tokens, transaction/receipt numbers), risk/fraud screening data, device/browser information, and IP address (when used).
Purposes: Payment processing (including wallet, card, and, where applicable, “Pay Later”), authorization/billing, fraud prevention, legal obligations (e.g., anti-money laundering).
Legal bases: Art. 6(1)(b) GDPR (payment processing/contract), (f) (fraud prevention/IT security), (c) (legal obligations).
Transfers to third countries: Depending on the circumstances, data may be transferred to group companies or servers outside the EEA (U.S.); in which case the safeguards provided for under the GDPR are used (e.g., adequacy decision/DPF, standard contractual clauses).
Retention period: In accordance with the legal obligations of the payment service; T&D Agri does not store complete card data (only transaction/proof data).
- Stripe:
Data Controller/Service: Stripe Payments Europe/Technology Europe (Ireland); Group company Stripe Inc. (U.S.).
Categories of Data: Name, email, billing/shipping address, payment/transaction data (amount, currency, Payment Intent/Charge ID, token), card metadata (last 4 digits, card type, expiration date), SEPA/bank details (if used), device/browser information, IP address, risk/fraud indicators.
Purposes: Payment processing (card, SEPA, etc.), tokenization of card data, fraud prevention/3-D Secure, billing, legal obligations.
Legal bases: Art. 6(1)(b) (contract/execution of payment), (f) (fraud prevention/IT security), (c) (legal obligations).
Transfers to third countries: Depending on the product or support service, processing may be carried out by Stripe entities in the U.S.; safeguards are provided through an adequacy decision, DPF, or standard contractual clauses.
Retention period: In accordance with the legal obligations of the payment service; T&D Agri does not store full card data (only necessary verification and transaction data).
- Auxilia:
- Integration to services / platforms / social networks
This is not immediately apparent from the public section of the website. Please let us know if these services are used here.
- Links to other websites
The T&D Agri website may contain links to other websites. T&D Agri has no control over those websites’ compliance with data protection regulations; therefore, this Privacy Policy does not apply to such websites.
- Retention period
We will store your personal data for as long as necessary to fulfill the purpose of the data processing. In addition, data will be stored only to the extent that there is a corresponding legal obligation or pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data necessary to comply with accounting obligations (Sections 190, 212 of the Austrian Commercial Code (UGB)) and tax law requirements (Section 132 of the Austrian Tax Code (BAO)) will be retained for at least 10 years. In addition, in individual cases, data may be retained for a longer period until the conclusion of a legal dispute or until the expiration of warranty periods and statutes of limitations for the assertion of claims for damages, if necessary.
- Other data is generally deleted 5 years after the business relationship ends. Data will only be retained beyond this period if there is a legal obligation to do so.
F. Data collection by T&D Agri from its partners in connection with the use of the WineWallet directly to WineWallet shipping option
T&D Agri collaborates with certain winemakers and wine shops, and as part of this collaboration, allows T&D Agri customers with winewallet active winewallet to have orders placed with these partners delivered directly to T&D Agri. For this purpose, certain plugins or workflows are integrated into the partner’s online stores, which automatically extract specific data defined by T&D Agri from the (non-public) order form or shopping cart of the online store and, depending on the partner’s settings, transmit personal data in JSON format via email to T&D Agri upon completion (and, if applicable, payment) of the order by you or upon receipt of an order confirmation from the partner to you.
- Source of Data Collection
Partners | public / non-public source |
Dorli Muhr Winery (FN 516614 b) in Prellenkirchen
| not public |
Heribert Bayer, Kellerei In Signo Leonis GmbH (FN 256637h) in Neckenmarkt
| not public |
May Wines KG, FN 478902 v in Vienna | not public |
- Categories of Personal Data Collected
T&D Agri processes the following categories of personal data in connection with the plugins integrated into its partners’ online stores:
- First and last name;
- Email address;
- Order details (name and domain of the partner's online store, products, product names, bottle size, producer, grape variety type, grape variety, country of origin of the grape variety, purchase price, vintage, quantity, condition (fill level, cork, label))
- Purposes of Processing
The processing of personal data collected by our partner is limited to the data necessary for order fulfillment, storage at T&D Agri’s warehouse, and display in the user account.
In particular, data processing is carried out for the following purposes:
- organizing the storage of the ordered bottles of wine at the T&D Agri warehouse;
- communication with the customer regarding the order placed with the partner; and
- the display of the wines to be stored in the customer's account even before they have arrived at the T&D Agri storage facility;
- Legal Basis
T&D Agri processes the personal data collected from its cooperation partner on the following basis, in accordance with Article 6(1) of the GDPR:
- The use of the data specified in Section 1 is necessary for the fulfillment of the winewallet and for the related storage and display of information in the user account (Article 6(1)(b) of the GDPR).
There is no obligation to provide the personal data we request from the partner. However, you will not be able to use the WineWallet shipping option if you do not provide your personal data or if we do not collect this personal data from the partner. If the collection of your data is required by law in certain cases, we will notify you separately.
- Disclosure of data to third parties
For the purpose of a possible reversal of the transaction, the personal data listed above will be returned to the partner.
Other than that, the data mentioned above will not be disclosed to third parties or transferred to third countries or international organizations.
- Retention period
We will store your personal data for as long as necessary to fulfill the purpose of the data processing. In addition, data will be stored only to the extent that there is a corresponding legal obligation or pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data necessary to comply with accounting obligations (Sections 190, 212 of the Austrian Commercial Code (UGB)) and tax law requirements (Section 132 of the Austrian Tax Code (BAO)) will be retained for at least 10 years. In addition, in individual cases, data may be retained for a longer period until the conclusion of a legal dispute or until the expiration of warranty periods and statutes of limitations for the assertion of claims for damages, if necessary.
- Other data is generally deleted 5 years after the business relationship ends. Data will only be retained beyond this period if there is a legal obligation to do so.
G. Data Processing During the Application Process
- Categories of Personal Data Collected
T&D Agri regularly seeks employees for a wide variety of positions and professional fields. Applications may be submitted via the email addresses listed in the job postings. As part of the application process, T&D Agri processes the following personal data:
- Name
- Title (Mr./Ms./Other), including academic titles
- Name suffix
- Photo (if provided)
- Gender
- Marital Status and Children
- E-mail address
- Phone number
- Address
- Country of residence
- Citizenship
- Date of Birth, Place of Birth
- Driver's license (yes/no)
- Position you would like to apply for
- Type of application (e.g., email, unsolicited application—yes/no)
- Information regarding how to find the job posting
- Earliest Start Date
- Notice Period
- Salary Expectations
- Resume, Certificates, and Transcripts
- Military Service/Civilian Service
- Education (School, University, Courses)
- Previous Work Experience
- personal skills and competencies
- Signature
- Other information derived from the submitted documents, such as a resume, transcripts, etc., including any photos
- Notes from the Job Interview
- Communication Data (including email correspondence)
- Other data you provide as part of your application
- Purposes of Processing
The processing of personal data as part of the application process is limited to the data necessary to process an application.
In particular, data processing (including photos) is carried out for the following purposes:
- processing a (spontaneous) application / assessing suitability for an advertised position;
- contacting applicants;
- the application process
- record-keeping (if consent is given);
- Legal Basis
T&D Agri processes personal data related to the application process on the following basis, in accordance with Article 6(1) of the GDPR:
- The use of the personal data (including a photo) referred to in item 1 is based on the pre-contractual measures associated with the application (Article 6(1)(b) of the GDPR).
- The use of the personal data specified in point 1 (including a photo) is also necessary to safeguard the legitimate interests of T&D Agri as a potential future employer, as well as to ensure an efficient application process and optimal staffing (Article 6(1)(f) of the GDPR).
- The retention of the personal data referred to in point 1 (including a photo) is based solely on (explicit) consent (Article 6(1)(a) of the GDPR).
You have the right at any time to withdraw your consent to the use of your personal data for record-keeping purposes. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent has no effect on data processing based on another legal basis.
You are under no obligation to provide us with the personal information we request or to submit your application materials. However, your application cannot be processed if you do not provide your personal information. If providing your information is required by law in certain cases, we will notify you separately.
- Disclosure of Data to Third Parties
In order to achieve the processing purposes we have specified, it may sometimes be necessary for us to disclose your data to specific recipients.
Further down in this text, you will find a list of controllers and processors to whom we may, on a case-by-case basis, transfer, provide, or otherwise make personal data available. Where it is not possible to name specific recipients here, the GDPR allows us to specify categories of recipients.
In some cases, we intend to transfer personal data in this context to data controllers and/or data processors that are not based within the European Economic Area. In the following, we therefore provide additional information about which recipients are based in a third country and the legal basis on which we transfer data to these recipients.
Where applicable, we transfer personal data based on an adequacy decision by the European Commission. If no such decision exists, we transfer personal data only in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient, or based on an exception expressly provided for by law. A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding recipient categories: If the table below lists only categories of recipients and the table does not expressly state otherwise, we generally do not intend to transfer personal data to data controllers and/or data processors that are not established within the European Economic Area, unless you establish such a connection to a third country in a specific case. If, in exceptional cases, you establish a connection to a third country (e.g., because we must enforce an outstanding claim against you in a third country or because you have requested that we ship wines to you in a third country), we will transfer personal data, where applicable, based on an adequacy decision by the European Commission. If no such decision exists, we will transfer personal data exclusively in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient or on the basis of an exception expressly provided for by law (e.g., your consent). A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding data transfers to the U.S.: In particular , the website uses standard third-party cookies and services provided by companies based in the U.S., which are described in more detail below. These are used with your consent, and personal data may then be transferred, in particular, to the U.S. servers of the respective companies. The U.S. is not a safe third country and does not meet the data protection standards required under EU data protection law. Due to the legal situation in the U.S., recipients there may be required to disclose personal data to law enforcement agencies. As a data subject, you have no recourse against this. It therefore cannot be ruled out that U.S. authorities and security services may process personal data for surveillance purposes, over which T&D Agri has no further control.
Our job postings are also published on third-party platforms (including LinkedIn, karriere.at, and weinjobs.at). If you apply directly through these platforms (“Easy Apply,” application form on the portal), the respective platform will process your personal data under its own responsibility in accordance with its privacy policy.
We receive your application materials via the platform (e.g., download from the portal or forwarding via email) and process them solely for the purpose of handling your application. There is no automated transfer to our CRM; data is stored in our internal systems (e.g., email/file storage) only to the extent necessary for the application process (see G.3 above for the legal basis).
You may exercise your rights to access, erasure, and other data subject rights directly with the respective platform; with regard to our processing, the rights described in this section apply.
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country |
IT service providers used | EEA/specific third country | Not required /
|
Companies that are part of our group
| EEA | not required |
- Retention period
Unless a hiring decision is made, the data required to process the (unsolicited) application and to assess suitability for the advertised position will be stored for up to 7 months after the conclusion of the application process, in accordance with the applicable legal provisions (§§ 20 in conjunction with 17 GlBG, §§ 7k(1), (2)(1) in conjunction with 7e(1) BEinstG) for up to 7 months after the conclusion of the application process.
If you have given your consent for us to retain your application on file, your application will be stored for a period of 12 months after the application process has ended. Consent to retain an application on file may be revoked at any time. In this case, personal data will no longer be processed and will be stored only to the extent required by applicable legal retention obligations.
Regardless of the above, we will retain your data for as long as (i) statutory retention requirements apply or (ii) any legal claims for which the personal data is required to assert or defend against them have not yet become time-barred.
H. Data Processing in Connection with Contests
Users can regularly enter contests on the T&D Agri website. In such cases, the personal data provided by the user when entering the respective contest will be stored and used to administer the contest and, if prior separate consent has been given, to send promotional materials.
- Categories of Personal Data Collected
T&D Agri processes the following categories of personal data in connection with participation in sweepstakes:
- Name
- E-mail address
- Country of residence
- Date of birth and age (for age verification)
- Address
- Purposes of Processing
T&D Agri processes your data for the following purposes:
- Age verification for compliance with legal dispensing restrictions,
- Organization and administration of sweepstakes, contests, and other competitions, including notification of winners and awarding of prizes,
- Sending promotional and marketing information about T&D Agri’s services and events, provided you have given your separate consent,
- Legal Basis
T&D Agri processes this personal data on the following legal basis:
- The data referred to in point 1 is used based on your or our overriding legitimate interest (Article 6(1)(a) and (f) of the GDPR).
You have the right to withdraw your consent to the use of your personal data at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent does not affect data processing based on another legal basis.
You are under no obligation to provide us with the personal data we request when you participate in sweepstakes. However, you will not be able to participate in sweepstakes if you do not provide your personal data. If providing your data is required by law in certain cases, we will notify you separately.
- Disclosure of Data to Third Parties
Data will not be disclosed to third parties or transferred to third countries or international organizations, except to the recipients expressly specified in the respective consent forms for the sweepstakes.
Alternatively, if specific details are already known: For the purposes of conducting the sweepstakes, your data will be transferred to [reason for using third-party providers…] due to the use of [reason for using third-party providers…].
- Retention period
We will store your personal data for as long as necessary to fulfill the purpose of the data processing. In addition, data will be stored only to the extent that there is a corresponding legal obligation or pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data necessary to comply with accounting obligations (Sections 190, 212 of the Austrian Commercial Code (UGB)) and tax law requirements (Section 132 of the Austrian Tax Code (BAO)) will be retained for at least 10 years. In addition, in individual cases, data may be retained for a longer period until the conclusion of a legal dispute or until the expiration of warranty periods and statutes of limitations for the assertion of claims for damages, if necessary.
- Other data is generally deleted 5 years after the business relationship ends. Data will only be retained beyond this period if there is a legal obligation to do so.
I. Data Processing Through Social Media Accounts
T&D Agri maintains an online presence on social media networks and platforms—particularly Facebook, Instagram, and LinkedIn—to communicate with customers, users, prospective clients, visitors, and job applicants who are active on those platforms and to provide them with information about T&D Agri and its services.
- Categories of Personal Data Collected
Through its online presence on various social media platforms, T&D Agri processes the following categories of personal data:
- Name
- Inquiries
- Purposes of Processing
T&D Agri processes your data for the following purposes:
- Effective Communication with Users
- Effective Communication with Users
- Provision of advertising and marketing information regarding T&D Agri's services and events,
- Presentation of Collaboration Partners
- Contests?
- Legal Basis
T&D Agri processes this personal data on the following legal basis:
- The use of the data referred to in point 1 is based on your consent or our legitimate interest (Article 6(1)(a) and (f) of the GDPR).
You have the right to withdraw your consent to the use of your personal data at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal. Furthermore, withdrawing your consent does not affect data processing based on another legal basis.
You are under no obligation to provide us with the personal data we request from you through our social media channels. However, you will not be able to use the services we offer through our social media channels or visit our profile if you do not provide your personal data. If, in certain cases, the provision of your data is required by law, we will notify you separately.
- Disclosure to Third Parties
In order to achieve the processing purposes we have specified, it may sometimes be necessary for us to disclose your data to specific recipients.
Further down in this text, you will find a list of controllers and processors to whom we may, on a case-by-case basis, transfer, provide, or otherwise make personal data available. Where it is not possible to name specific recipients here, the GDPR allows us to specify categories of recipients.
In some cases, we intend to transfer personal data in this context to data controllers and/or data processors that are not based within the European Economic Area. In the following, we therefore provide additional information about which recipients are based in a third country and the legal basis on which we transfer data to these recipients.
Where applicable, we transfer personal data based on an adequacy decision by the European Commission. If no such decision exists, we transfer personal data only in accordance with appropriate safeguards that ensure an adequate level of data protection on the part of the recipient, or based on an exception expressly provided for by law. A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding recipient categories: If the table below lists only categories of recipients and the table does not expressly state otherwise, we generally do not intend to transfer personal data to data controllers and/or data processors that are not established within the European Economic Area, unless you establish such a connection to a third country in a specific case. If, in exceptional cases, you establish a connection to a third country (e.g., because we must enforce an outstanding claim against you in a third country or because you have requested that we ship wines to a third country), we will transfer personal data, where applicable, based on an adequacy decision by the European Commission. If no such decision exists, we will transfer personal data exclusively in compliance with appropriate safeguards that ensure an adequate level of data protection at the recipient’s end or on the basis of an exception expressly provided for by law (e.g., your consent). A copy of the documentation regarding the appropriate safeguards or other legal bases for the transfer to a third country is available upon request (see contact information (Section B)).
Note regarding data transfers to the U.S.: In particular, the website uses standard third-party cookies and services provided by companies based in the U.S., which are described in more detail below. These are used with your consent, and personal data may then be transferred, in particular, to the U.S. servers of the respective companies. The U.S. is not a safe third country and does not maintain an adequate level of data protection as defined by EU data protection law. Due to the legal situation there, recipients in the U.S. may be required to disclose personal data to law enforcement agencies. As a data subject, you have no recourse against this. It therefore cannot be ruled out that U.S. authorities and security services may process personal data for surveillance purposes, over which T&D Agri has no further control.
Your data may be transferred to the following recipients or categories of recipients; if transferred to third countries, this is done on the following basis:
Recipient or category of recipients | EEA or third country? | Legal Basis for Transfer to a Third Country |
IT service providers used | EEA/specific third country | Not required /
|
Companies that are part of our group
| EEA | not required |
- Social media platform operators
In addition to the data processing carried out by T&D Agri, the operators of the social network also process the personal data of social network users, including your data. However, we have no influence whatsoever over this data processing, which is carried out exclusively under the responsibility of the social network operators. If you are asked to consent to data processing (e.g., by checking a box or clicking a button), the legal basis for the processing is Article 6(1)(a) of the GDPR. For a detailed description of the respective processing activities and the options for objecting (opt-out) provided by the operators of the respective social networks, please refer to the information linked below from the operators.
Please note, however, that in Case C-210/16, the European Court of Justice ruled that the operator of a “fan page” maintained on a social network is also a controller within the meaning of the GDPR (in addition to the operator of the social network—in this case, specifically Facebook)—and thus acts as a joint controller, together with the social network operator, for the data collected by the social network operator. However, unless absolutely required by law or case law, T&D Agri cannot assume any responsibility toward you for the processing of your personal data by the operators of social networks.
T&D Agri also notes that data may be processed by the operators of the respective social networks outside the European Economic Area. This may pose risks to users due to differing legal frameworks, as it could, for example, make it more difficult to enforce users’ rights. In this context, we refer you to the terms of use and privacy policies of the respective social network operators (see links below).
With regard to requests for information and the exercise of user rights concerning data processing by social media platform operators, we would like to point out that these rights can be exercised with the social media platform operators listed below. Only the operators have access to user data and can take appropriate action and provide information directly.
- LinkedIn: ( LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Facebook: ( Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy Policy:https://www.facebook.com/about/privacy/, Opt-Out:https://www.facebook.com/settings?tab=adsand https://www.youronlinechoices.com/at/praferenzmanagement.
- Instagram: ( Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/Opt-Out:http://instagram.com/about/legal/privacy/.
- Retention period
We will store your personal data for as long as necessary to fulfill the purpose of the data processing. In addition, data will be stored only to the extent that there is a corresponding legal obligation or pending legal claims arising from a legal relationship concerning the data that require longer-term storage. This results in the following for the processing purposes we pursue:
- Data that we process in connection with your (purely informational) visit to the T&D Agri Online page on the respective social network will be stored until you log out of that social network.
- Data necessary to comply with accounting obligations (Sections 190, 212 of the Austrian Commercial Code (UGB)) and tax law requirements (Section 132 of the Austrian Tax Code (BAO)) will be retained for at least 10 years. In addition, in individual cases, data may be retained for a longer period until the conclusion of a legal dispute or until the expiration of warranty periods and statutes of limitations for the assertion of claims for damages, if necessary.
- Other data is generally deleted 5 years after the business relationship ends. Data will only be retained beyond this period if there is a legal obligation to do so.
J. Data Security
- Website
During a visit to the website, the widely used […] method is employed in conjunction with the highest encryption level supported by the browser being used. Whether a particular page of the website is being transmitted in an encrypted manner can be determined by the closed appearance of the key or lock icon in the browser’s address bar.
- General Data Processing
In addition, appropriate technical and organizational precautions and security measures are generally applied during data processing. These measures are designed, in particular, to protect against unauthorized, unlawful, or accidental access; accidental or intentional manipulation; processing; partial or complete loss; destruction; and misuse. These security measures reflect the current state of the art.
Notwithstanding our efforts to maintain a consistently high standard of due diligence, we cannot rule out the possibility that information disclosed to us via the Internet may be viewed and used by others.
Please note that, as a result, no liability of any kind can be accepted for the disclosure of information due to errors in data transmission not caused by T&D Agri and/or unauthorized access by third parties (e.g., a hacker attack on an email account, interception of communications).
- Disclosure of Data Breaches
T&D Agri wants to ensure that data breaches are recognized at an early stage and, if necessary, reported immediately to you or the responsible supervisory authority, taking into account the respective data categories that are affected.
K. Changes to This Privacy Policy
Our Privacy Policy may change over time in line with the evolution of our business objectives or due to external factors (e.g., an adjustment required by new case law). We will post such changes on our website.