Data protection declaration

IP Austria Communication GmbH (IPA) and Your Personal Data

As one of the leading providers of communication technology and related services and products, IPA is committed to using
state-of-the-art technologies to protect the personal data of our customers and visitors to our websites as effectively
as possible.

What is personal data?

Personal data is data that can be used to identify you personally, such as your name, address, e-mail address, telephone number, etc. When you visit the website, further data is added for technical reasons, such as your IP address, Internet access provider, etc. Data is not personal if it does not relate to a specific person. Statistical data that is collected, for example, when you visit the web store and that cannot be directly linked to you personally is therefore not personal data. (e.g. statistics on which pages on IPA’s website are particularly popular or how many users visit certain pages).

What data does IPA process?

IPA collects and processes master data and metadata as well as other personal data provided by you in the context of the contractual relationship and by third parties in the context of verifying the identity, business capacity and creditworthiness of the customer.

Master data.

Master data refers to the personal data that you provide to IPA, particularly when concluding a contract,
. This includes your name, residential address, academic degree, telephone number, contact information such as your
e-mail address, information about the type and content of the contractual relationship and your creditworthiness data.
For
companies, the master data also includes the company name, address and company register number.
IPA deletes the master data relating to the customer no later than seven years after all claims arising from the
contractual relationship have been settled.

Metadata (formerly traffic data).

Metadata, formerly known as traffic data, refers to all data that is processed for forwarding a message to a
communication network or for billing this process. This includes, for example, active and passive
subscriber numbers, device, charge code, total number of minutes to be charged for the billing period; type,
date, time and duration of a connection or other use; amount of data transmitted; routing; the
protocol used; the network from which the message originates or to which it is sent; message format.

Telephony and data service

Master data and traffic data are processed to fulfill the contractual obligation of the telephony and data service in
order to establish, control and bill telecommunication connections. With your invoice you will also receive
web access to your online individual call records (the last 3 digits of the telephone numbers you have called are not
displayed at). On request, we also offer an unabridged itemized bill. This can only be requested in advance.

Operational purposes

IPA processes metadata only to the extent that personal data is absolutely necessary for operational purposes (in
particular troubleshooting problems with the
connection setup, network requirements analyses, performance analyses, further development and planning of the network
expansion, optimization of offers as well as analysis and prevention of fraudulent activities to the detriment of IPA).
Metadata stored for these purposes is deleted or anonymized after 6 months at the latest .In order to ensure
communication, IPA works together with various service providers and partners (e.g.
termination partners), who also have access to the technical systems and data for troubleshooting purposes.

Transfer of personal data to third parties

Your data will be used exclusively for the provision of our service and will of course not be passed on to third parties
without your explicit consent. Under no circumstances will your data be sold or marketed. An exception to this is the
forwarding of data to authorities if there is a legal obligation to do
so. Our employees and partners who may gain knowledge of your personal data through maintenance and services
are contractually bound to secrecy.

You have these rights

– If the stored data is incorrect, you can contact us at any time by telephone, e-mail or fax at
for correction.
– You have the right to obtain information free of charge at any time about the personal data stored about you, its
origin and recipients and the purpose of the data processing.
– You also have the right to have your data deleted.
– Should there ever be cause for complaint about the processing of your data, you can also contact the data protection
authority at at any time.

Further information

Your trust is important to us. We would therefore be happy to answer any questions you may have regarding the processing
of your personal data. If you have any questions that are not answered by this privacy policy or if you would like more
detailed information on any point, please contact us:
IP Austria Communication GmbH
“IPA-Datenschutz”

Data processing in connection with the contract

Telephony to a foreign network (domestic or international)
If you call from an IPA network to another network (domestic or international), your traffic data is transmitted to
, the so-called interconnect partner, and to the operator of the destination network.

Processing your order on IPA.

We collect the following personal data to process your order:

  • First and last name,
  • Address,
  • E-mail address,
  • Telephone number,
  • Date of birth and ID number or company register extract as well as your
  • Bank details

We need this to confirm your order by e-mail, to deliver the ordered goods, to issue the invoice and the
contract document for the respective tariff. If your delivery address differs from your billing address,
will also save the delivery address.
The goods you have ordered will be delivered by parcel services. For the delivery of the goods, the parcel service
receives your order data such as name and address.
The data stored by the parcel service will be deleted after the statutory limitation period has expired.

Contract conclusion with a partner of IPA.

If you conclude the contract with a sales partner of IPA, the following personal data will be transmitted for billing
between IPA and this
partner: Name, address, telephone number and tariff.

Determination of your identity

.
When you sign the contract, IPA verifies your identity to protect itself against fraud. For this purpose, your photo ID
is checked for accuracy. If it turns out that the photo ID is forged, you will not be able to conclude the contract.
In this case, the scanned photo ID will be deleted after six months.
The copy of the photo ID is stored for the duration of your contract and is automatically deleted after the contract is
terminated at.

Creditworthiness check.

IPA can check your creditworthiness to protect itself against misuse. For this purpose, your master data is forwarded to
officially authorized credit protection associations, credit institutions and traders who are authorized to do so and
compared. The recommendation regarding solvency and willingness to pay is calculated on the basis of the statistical
probability of the following parameters: qualified payment defaults (debt collection entries, insolvency, etc.),
age and place of residence.

Invoicing

Corporate and legal obligations.
For accounting, business and legal reasons, master data and metadata of customers and
suppliers are processed, analyzed and stored by IPA. All tax-relevant records are stored at
in accordance with legal requirements.

Invoicing

You can decide whether you would like to receive invoices by e-mail or by post. When you activate e-invoicing at, an
e-mail will be sent to the e-mail address you have specified for this purpose, which you verify by clicking on the
confirmation link.
Master data and metadata are used for invoicing. The master data and product data
can be found directly on the invoice. The metadata is required to calculate your invoice.
You can also find all invoices in your Admin Portal. There you can also retrieve the shortened
individual call records (the last 3 digits of the phone number are not displayed), which are deleted after 6 months. If
you would like to receive an unabridged itemized bill, you must request this in advance at.
In the event of a billing objection, the metadata and therefore also your individual call records will be stored until
the final decision is made. The invoices will be stored for the duration of the statutory retention period of 7 yearss.

Payment of the invoice

To settle the invoice, the payment method you have specified (SEPA direct debit) is used for an
automatic payment collection. IPA works together with banks to collect payments. Data is transmitted in encrypted form.
You can revoke your consent to the collection at any time, without giving reasons, with effect for the future by
telephone or by e-mail. If you transfer the outstanding invoice amount to IPA yourself (whether by telebanking or
payment slip at
the bank),
will automatically allocate the payment to your customer account at IPA using your master data, which IPA receives from
the banks for.

Reminders

In order to initiate appropriate reminders in the event of late payment or non-payment of the outstanding
balance on your part, your master data and details of the due
invoices will be used by IPA to fulfill your contractual obligations.

Collection

In the event of late payment or non-payment of the outstanding balance, your customer data (name, address, e-mail
address provided to and confirmed by
, date of birth, gender, profession, telephone number, contract copy and
a copy of your ID if required) and details of the relevant arrears (invoices,
account statement) will be sent to a debt collection agency or to lawyers to collect the debt. This data will be deleted
by the debt collection agencies seven years after collection has been completed.
Your customer data (name, address, etc.) and creditworthiness data will be transmitted to officially authorized credit
agencies for the purpose of creditor protection only with your express consent in the event of late payment. You can
revoke the transmission of the data with effect for the future at any time by telephone or email without giving reasons.

Restriction of services

To protect against fraud and to protect you from large financial charges, metadata is processed to determine the
current invoice amount. If an unusually high amount is reached, IPA may restrict the scope of services
and ask you to make an advance payment or provide security.

Objection/complaint processing

In complaint and objection cases, IPA accesses the master, meta, payment and
profile data and customer interactions stored in databases that are required to review the complaint. If you dispute
services from third-party providers, your call or customer number, the order numbers
of the services and the internal processing number of IPA will be transmitted to the third-party provider concerned if
necessary to clarify the matter, provided that express consent is given in the form provided for this purpose at. If you
contact an arbitration board, an interest group or a lawyer and an objection is submitted to
on your behalf, IPA will forward your above-mentioned personal data to the arbitration board or interest group or the
lawyer required to clarify the objection case. The personal data described
above will not be deleted as long as the proceedings are ongoing. Thereafter,
the general retention and deletion periods apply.

Cancellation of the contract

If you terminate your contract, your personal master data and stored customer interactions will be deleted after 3.5
years, as you can assert your civil law claims within a period of three years. However, if
the contract is terminated by IPA due to late payment, the retention period may be extended until
all claims have been settled.

Extraordinary termination – processing of special cases

If there is an extraordinary reason for termination, for example due to guardianship or in the event of death, the
master data and metadata required for this, as well as notices and documents, will be transmitted to third parties such
as notaries, lawyers, mass administrators or custodians if necessary.

Legal obligations

Telephone directory entry When concluding the contract, you can expressly consent to being included in directories of
subscribers (telephone
directory entry). If you agree to the entry, you acknowledge that these generally also enable searches to be carried out
using data other
than your name. You can revoke your consent at any time without giving reasons by contacting customer service at. Please
note that our
partners may also take some time to process your request before the entry is deleted.

Assaults and emergencies

As an IPA customer, you have the option of contacting IPA if you are being harassed by a particular caller. In this
case, you have the option of setting up a chargeable intercept for future calls to IPA, including suppressed
calls. The caller will be identified with this trap.

Emergency calls

If an emergency call is made to an emergency call service (ambulance, fire department, police, etc.), IPA is obliged to
provide with information about your master data and location data at the request of the emergency call service.
You will be informed by IPA about the time and type of data transmitted by the requesting
network operator after 30 hours at the earliest.

Monitoring

IPA is obliged to cooperate in the monitoring of messages and the provision of information about data from a message
transmission (including metadata and location data, master data) to the extent required by law. Data is transmitted to
the authorities via an encrypted system.
All data is stored at IPA for the duration of traceability

Communication and information

Advertising for you
If you expressly agree to receive customized advertising from IPA, your customer data such as email address, telephone
number or address will be used for this purpose. If you are not a
contract customer of IPA (e.g. with a telephony and/or data tariff), the double opt-in procedure is
used, in which it is ensured by confirming your e-mail address again that you have agreed to receive the advertising.
You can revoke your consent at any time without giving reasons.

Sending you important information about your contract
In some situations, IPA is legally obliged to inform you. This may be, for example, a
change to your contract (e.g. an adjustment to the basic monthly fee or a change of tariff), the discontinuation or
change of a certain service or a delay in the delivery of ordered devices. In other cases,
would like to inform you of planned changes in good time to save you any inconvenience.
For example, when planned maintenance work is carried out on our network in certain areas.
In order to be able to inform you personally, we will process your master data and additional information such as your
current tariff, additional services you use or devices you have purchased from IPA.
This information is sent to you, for example, by e-mail, telephone, post or on your monthly invoice.
IPA works together with postal or parcel services for postal delivery.

Profiling

Profiling means analyzing the user behavior of customers. IPA does not use profiling!

IPA business customers

Invitations to customer events.
IPA organizes events on various topics for its business customers and thus also offers a platform for
networking. The events are planned and organized by IPA together with various partner agencies. Master data is processed
for the invitation and the guest list and, if necessary, transmitted to the partner agencies.
In order to optimize the planning of future events, acceptances and cancellations of the invited
persons are evaluated after each event. This information will be deleted no later than 36 months after the end of the
contract. If you do not wish to be invited to IPA events, you can object to this at any time by calling
or sending an e-mail.

Customer service

IPA processes the master and traffic data stored in the systems as well as
customer interactions that are necessary to answer the query or solve the existing problem in order to process your
queries and objections, for example regarding the invoice, customer-related products and services or
technical problems. Such a request may, for example, concern changing address or bank details, requesting individual
call records, setting
blocks or activating/deactivating services. In order to identify you as a customer, will first request your customer
password. An entry is made in our support system for each customer contact. With your
consent, IPA employees can also access your
IPA Admin Portal in order to make changes there in accordance with
your order. Every access is saved in the IPA support system.

IPA Admin Portal

The IPA Admin Portal is a customer account with password-protected access. Here you can view the
tariff you have taken out and manage your address details, bank details, subscribed services such as newsletters or the
tariff security limit. You can also view your invoice and change your password.
You undertake to treat your personal access data confidentially and not to make it accessible to any unauthorized third
parties. IPA accepts no liability for misused passwords, unless IPA is responsible for the misuse.
The IPA Admin Portal is automatically deleted 6 weeks after termination of the contract.

Calls to IPA

When you call IPA, the following information is processed by the telephone system in order to always connect you to the
correct contact at:

  • The number you are calling with
  • Date and time of the call

Written Communication with IPA

You can contact IPA in writing using the contact form, email, fax, or letter.

Complaints

If you hand over devices to IPA for repair, your master and device data will be documented in a dedicated support system
so that the repair status can be read. If you agree that the device may be passed on to a repair partner during repair,
they will contact you directly if they have any questions. In this case, your phone number or email address will also be
sent to the partner. This consent can be revoked at any time, without giving reasons, with future effect. Your
complaints will be logged in the IPA support system. In order for IPA to determine from customer support whether
your device is still covered by a warranty and whether the product can be repaired or replaced, the relevant information
stored about your contract is reviewed in the support system.

Business inquiries.

Interested business customers
If you contact IPA via the contact form on IPA, by phone, or by other means as a prospective business customer, your
company master data will be processed for the purpose of establishing contact and submitting an offer.

The stored data will be deleted if no contract is concluded within 3 months and you have not consented to longer storage
of your master data. You can revoke your consent with effect for the future
at any time and without giving reasons.

Google Analytics

This website uses the “Google Analytics” service, which is provided by Google Inc. (1600 Amphitheatre Parkway, Mountain
View, CA 94043, USA), based on our legitimate interests in optimizing and analyzing our online offering within the
meaning of Art. 6 (1) (f) GDPR. The service (Google Analytics) uses “cookies” – text files that are stored on your
device. The information collected by the cookies is usually sent to a Google server in the USA and stored there.

Google LLC complies with European data protection law and is certified under the Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

IP anonymization is active on this website. Users’ IP addresses are shortened within the member states of the EU and the
European Economic Area, as well as in other states party to the agreement. Only in exceptional cases is the IP address
initially transmitted unabridged to a Google server in the USA and shortened there. This shortening eliminates the
personal reference to your IP address. The user’s IP address transmitted by the browser is not combined with other data
stored by Google.

As part of the data processing agreement we, as the website operator, have concluded with Google Inc., Google uses the
collected information to evaluate website usage and website activity and to provide services related to internet usage.

The data collected by Google on our behalf is used to evaluate the use of our online offering by individual users, e.g.,
to compile reports on website activity in order to improve our online offering.

You have the option of preventing cookies from being stored on your device by selecting the appropriate settings in your
browser. There is no guarantee that you will be able to access all functions of this website without restrictions if
your browser does not accept cookies.

You can also use a browser plug-in to prevent the information collected by cookies (including your IP address) from
being sent to and used by Google Inc. The following link will take you to the corresponding plug-in: https://tools.google.com/dlpage/gaoptout?hl=de

Alternatively, you can prevent Google Analytics from collecting data about you on this website by clicking on this link
Google Analytics
deaktiv
. By clicking on the link above, you will download an “opt-out cookie.” Your browser
must therefore generally allow cookies to be stored. If you delete your cookies regularly, you will need to click the
link again each time you visit this website.

You can find further information about data usage by Google Inc. here:
· https://policies.google.com/privacy/partners?hl=de
(Data collected by Google partners)
· https://adssettings.google.de/authenticated (Settings
regarding the advertising displayed to you)
· https://policies.google.com/technologies/ads?hl=de
(Use of cookies in ads)