Privacy Policy

1. Data Controller

Volturi GmbH
Dr. Natterer-Gasse 4a/ Top 57
1020 Vienna
Austria

Email: info@susanno.com

Managing Director: Sultan Rolle

2. General Information

This Privacy Policy informs you about the type, scope, and purpose of the processing of personal data (hereinafter "data") in our online shop, including newsletter registration and the use of marketing, tracking, and analytics tools.

3. Processed Data

We process the following categories of personal data:

  • Customer Data: e.g. name, address
  • Contact Data: e.g. email address, phone number
  • Content Data: e.g. entries in forms
  • Usage Data: e.g. visited pages, access times
  • Meta/Communication Data: e.g. IP address, device data
  • Marketing Data: information from tracking and analytics tools such as Facebook Pixel and Google Analytics

4. Purpose of Processing

The data is processed for the following purposes:

  • Fulfillment of contractual obligations, order processing, and responding to inquiries
  • Sending our newsletter (if subscribed)
  • Optimization and further development of our services
  • Analysis of user behavior (Google Analytics, Facebook Pixel)
  • Delivery of personalized advertising (e.g., via Facebook and Google)

5. Legal Basis

Your data is processed on the following legal grounds:

  • Art. 6 (1) (b) GDPR: processing necessary for the performance of a contract (e.g., order processing)
  • Art. 6 (1) (a) GDPR: processing based on your consent (e.g., newsletter, marketing tools)
  • Art. 6 (1) (c) GDPR: compliance with legal obligations (e.g., tax retention obligations)
  • Art. 6 (1) (f) GDPR: legitimate interests (e.g., analytics tools and security measures)

6. Newsletter

We use “Klaviyo” for sending newsletters, an external service provider acting as a processor in accordance with Art. 28 GDPR. Your data is transferred on the basis of Standard Contractual Clauses (EU SCCs) to ensure an adequate level of protection.

Klaviyo Inc.
125 Summer St, Boston, MA 02110, USA

After subscribing, you will receive an email to confirm your subscription (double opt-in process). You can unsubscribe at any time via the "unsubscribe" link in each newsletter or by contacting us at info@susanno.com.

7. Tracking and Marketing Tools

We use the following tools for analytics and personalized marketing:

Facebook Pixel

We use Facebook Pixel to analyze visitor behavior and deliver personalized ads on Facebook and Instagram. Facebook Pixel collects data about your usage of our website, which is transmitted to Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA.

The use of Facebook Pixel is based on your consent under Art. 6 (1) (a) GDPR. You can revoke consent at any time in your Facebook account settings or by restricting cookies in your browser.

Google Analytics

We use Google Analytics to analyze usage behavior. Information generated by cookies about your use of our website is transmitted to a Google server in the USA and stored there. Google uses this information to evaluate your use of the website and to compile reports on website activity.

Processing is based on your consent under Art. 6 (1) (a) GDPR.

Google Tags

Our website uses Google Tags to manage analytics and tracking tags, enabling centralized control of our marketing and analytics tools.

8. Data Accuracy

We take measures to ensure that personal data processed by us is accurate and up to date. You have the right to review and correct inaccurate personal data.

9. Disclosure of Data

Your personal data will only be shared with third parties when necessary for contract fulfillment (e.g., shipping and payment providers). Data will not be shared for advertising purposes without your explicit consent.

10. Payment Processing

We use external payment providers such as PayPal or Stripe for processing payments. These providers act as independent controllers under the GDPR.

11. Cookies

We use cookies to make our website easier to use, safer, and to analyze user behavior. For technically necessary cookies, the legal basis is Art. 6 (1) (f) GDPR (legitimate interests). For all other cookies, we request your consent in accordance with Art. 6 (1) (a) GDPR. You can prevent cookies from being stored in your browser, but this may limit the functionality of our website.

12. Security Measures

We use technical and organizational security measures to protect data from manipulation, loss, or unauthorized access. These measures are continuously improved according to technological developments.

13. Data Breach

In the event of a data breach, we will immediately inform the competent data protection authority and affected individuals if there is a high risk to their rights. We have organizational procedures in place to ensure these obligations are met in a timely manner.

14. Your Rights

You have the right to:

  • Access your processed data (Art. 15 GDPR)
  • Rectify inaccurate data (Art. 16 GDPR)
  • Delete your data (Art. 17 GDPR)
  • Restrict processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Object to processing (Art. 21 GDPR)

To exercise these rights, contact us using the details above.

15. Right to Lodge a Complaint

If you believe that the processing of your data violates the GDPR, you may lodge a complaint with the competent supervisory authority:

Austrian Data Protection Authority
Barichgasse 40-42, 1030 Vienna
Email: dsb@dsb.gv.at

16. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy to comply with legal requirements or changes to our services. The current version is always available on our website.