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Legal

Privacy Policy

How we process personal data — under the GDPR and the Austrian TKG 2021.

Controller

Sprachzentrum Dialog e.U., owner: Mag. Mladen Nenadic
Franz-Fritsch-Straße 11, 4600 Wels
Warwitzstraße 9, 5023 Salzburg
Email: info@sprachzentrum-dialog.at
Phone: 0676 / 45 00 380

Purposes and legal bases of processing

  • Contact enquiries (contact form, email, phone): Art 6(1)(b) and (f) GDPR — to handle your enquiry, or on the basis of our legitimate interest in responding to it.
  • Course and exam bookings: Art 6(1)(b) GDPR — to perform or enter into the contract.
  • Invoicing and bookkeeping: Art 6(1)(c) GDPR together with the statutory 7-year retention requirement under §132 BAO (Austrian Federal Fiscal Code).
  • Newsletter: only with your explicit consent, Art 6(1)(a) GDPR together with §174 TKG 2021 (Austrian Telecommunications Act). We currently do not send a newsletter.

Recipients of data

We only share data where necessary to perform a contract or operate this website — with hosting and email service providers under a data processing agreement pursuant to Art 28 GDPR.

Transfers to third countries

Where service providers we use process data outside the EU/EEA, this happens only on the basis of appropriate safeguards (e.g. EU Standard Contractual Clauses or an adequacy decision by the European Commission).

Storage periods

We delete enquiry data once it is no longer needed to handle your request. Invoicing and bookkeeping records are retained for 7 years pursuant to §132 BAO.

Your rights

Under the GDPR you have the following rights:

  • Access to your stored data
  • Rectification of inaccurate data
  • Erasure of your data
  • Restriction of processing
  • Data portability
  • Objection to processing
  • Withdrawal of consent already given, with effect for the future

To exercise these rights, contact us at info@sprachzentrum-dialog.at.

Erasure and statutory retention (Art 17(3)(b) GDPR)

Draft — legal review pending

This section is a draft based on the researched legal framework and on how erasure is actually implemented; it has not yet been reviewed by a lawyer or tax advisor. That review will take place before go-live.

Under Art 17 GDPR you generally have the right to request the erasure of your personal data. That right does not, however, extend to data we are required to retain in order to comply with a legal obligation (Art 17(3)(b) GDPR).

As an Austrian business we are legally required to retain invoices and bookkeeping records for seven years (§132 BAO, the Austrian Federal Fiscal Code; §11 UStG for the mandatory content of an invoice; the retention duties of the Austrian Commercial Code, UGB). Invoice data — including the name and address shown on the invoice, which are a legally required part of it — can therefore only be deleted once that retention period has expired.

If you request the erasure of your data, we proceed as follows:

  • We anonymise your “live” personal data — name, contact details and address in your customer record, participant details, free-text notes, and documents you uploaded — and we block your account access, so that no further sign-in is possible.
  • The invoice records covered by the statutory retention duty (the issued invoices and the archived invoice PDFs) are kept unchanged until the seven-year retention period expires. During that time we process this data solely to meet our statutory retention and evidentiary obligations, and for no other purpose.
  • Once the statutory period has expired, those records are deleted or anonymised as well.

Technically, erasure is therefore implemented as anonymisation: your personal data is neutralised, while the accounting records required by law remain intact. The name and address frozen onto an invoice that has already been issued are legally mandated invoice content, not active account data.

How to exercise your right to erasure: if you have a customer account, you can submit the request yourself at any time under My Account → Privacy. Alternatively, an informal message to the controller (see the “Controller” section above) is sufficient — info@sprachzentrum-dialog.at. For security reasons the anonymisation is not triggered automatically: we review your request, then carry it out, and inform you of the outcome.

The controller for this processing is Sprachzentrum Dialog e.U.; addresses and contact details as above. VAT ID (ATU): to be added. There is currently no separate data protection contact address — please use the contact details given above.

Right to lodge a complaint

You have the right to lodge a complaint with the Austrian data protection authority:

Österreichische Datenschutzbehörde (Austrian Data Protection Authority)
Barichgasse 40–42, 1030 Vienna, Austria
www.dsb.gv.at

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