Russmedia Digital GmbH, the Austrian media company responsible for operating the website vol.at and its subdomains, has published a detailed privacy policy outlining how the organization processes personal data in compliance with the General Data Protection Regulation (GDPR) and other national data protection laws. The company, headquartered at Gutenbergstraße 1, 6858 Schwarzach, Austria, serves as the data controller for all personal information collected through their digital services.
The privacy policy defines personal data as any information that allows identification of an individual, including names, addresses, email addresses, and telephone numbers. According to the document, all personal data processing occurs exclusively based on legal provisions, including GDPR, the Telecommunications Act 2021, and national data protection laws. The company emphasizes that personal data is collected only when necessary for the requested purpose or when users voluntarily provide such information, following principles of data minimization and data economy.
The policy details numerous specific data processing activities across various services offered by vol.at. For newsletter services, the company processes user data based on consent under Article 6 of GDPR, with recipients including Salesforce in San Francisco, California, Magenta T-Mobile Austria GmbH in Vienna, Piano Software LLC in Amsterdam, and Inxmail in Freiburg, Germany. The company ensures appropriate safeguards for international data transfers, particularly citing Salesforce's certification under the Data Privacy Framework for transfers to the United States.
Registration services on the website require users to agree to vol.at's terms and conditions in connection with Article 6 of GDPR. The German company Evolver, located at Leipziger Str. 44, 09113 Chemnitz, serves as a recipient of personal data for registration purposes. Similarly, the company conducts contests and sweepstakes, processing personal data for winner selection based on contest terms and conditions, with data center operators serving as recipients of this information.
The platform offers various interactive features that involve personal data processing. These include feedback processing based on legitimate interests under GDPR Article 6, surveys and competitions conducted under vol.at's terms and conditions, and a WhatsApp news service that requires explicit user consent. The company also operates advertising services through Google Ireland Limited, requiring user consent for identity and company information sharing for advertising campaigns within the Russmedia Group.
Community engagement features represent a significant portion of the data processing activities. The company operates a citizen forum (Bürgerforum) to provide the latest news through vol.at, allowing readers to contribute content about their local communities through the "Meine Gemeinde" (My Community) feature. Additionally, a reader reporter service enables users to submit articles and images for potential publication on vol.at. All these community features operate under vol.at's terms and conditions in conjunction with GDPR Article 6.
The privacy policy describes a loyalty rewards program called "Ländle-Punkte" (Regional Points), where vol.at rewards user engagement with points for activities such as browsing, reading articles, commenting, sharing, and completing quizzes. Users can exchange these points for prizes or exclusive contest participation opportunities. The system also displays high scores achieved on the associated gaming website ländlejass.at, with both features requiring user consent under GDPR provisions.
Technical infrastructure components include paywall management systems operated through Piano Software LLC in Amsterdam and Atex Media Limited in Wells, Somerset, England, along with Evolver's single sign-on (SSO) services. All recipients of personal data remain within the broader Russmedia Group structure, with data processing continuing until users withdraw their consent.
Regarding user rights, the privacy policy provides comprehensive information about individual rights under GDPR. Users can request information about whether their personal data is being processed, seek correction or completion of inaccurate or incomplete personal data, and request restrictions on data processing under specific circumstances. The right to deletion allows users to request immediate removal of their personal data when it's no longer necessary for original purposes, when consent is withdrawn, or when data has been unlawfully processed.
Additional rights include the right to be informed about data correction, deletion, or processing restrictions communicated to third parties, and the right to data portability in structured, commonly used, and machine-readable formats. Users can object to data processing based on public interest or legitimate interests of the controller, particularly for direct marketing purposes including profiling activities.
The company addresses automated decision-making and profiling, ensuring users are not subject to decisions based solely on automated processing that produces legal effects or significantly affects them. For data protection inquiries, the company requests that users direct questions to datenschutz@russmedia.com, though they respond to inquiries received through any channel.
Users who believe their data protection rights have been violated can file complaints with supervisory authorities, particularly in their country of residence, workplace, or where the alleged violation occurred. In Austria, users can contact the Austrian Data Protection Authority (Datenschutzbehörde) at Barichgasse 40-42, 1030 Vienna, via email at dsb@dsb.gv.at or telephone at +43 1 521 52-25 69.
The privacy policy, last updated on April 19, 2024, applies exclusively to the vol.at website and its subdomains. The company advises users that when following links to other websites, they should review those sites' respective privacy policies directly. Russmedia Digital GmbH commits to updating this privacy notice whenever procedures change or technical adjustments occur, encouraging users to regularly review the current version of their privacy policy.
