PRIVACY POLICY

Data Controller

MS2 GmbH

Murtalstraße 641

5582, St. Michael im Lungau, AUT

Email: mario@ms2group.at

At MS2 GmbH, we take the protection of your personal data seriously. In compliance with Articles 13 and 14 of the EU GDPR and applicable Austrian law, we explain below how we process information you provide when using our websites (e.g. innovatorcircle.at).

1. Collected Data

  • Technical Data: IP address, browser type, device information, operating system, date/time, referring URL — collected automatically via cookies and analytics tools.

  • Contact Data: Name, email address, phone number if provided via forms.

  • Newsletter Data: Email address you voluntarily supply.

  • Optional: Usage data from digital services (e.g. which tools or sections you use).

2. Legal Basis for Processing

Data is processed under:

  • Consent (Art. 6 1(a) GDPR): when you opt-in to cookies or newsletters.

  • Legitimate Interest (Art. 6 1(f) GDPR): for site functionality, security, analytics, and service improvement.

  • Contractual Necessity (Art. 6 1(b) GDPR): if you sign up for any service or communication.

3. Cookies & Third‑Party Tools

We use essential, performance, and analytics cookies — some may involve third-party providers (e.g., Google Analytics). Persistent cookies require prior consent.

Your consent may involve transfers to countries outside the EU/EEA; we mitigate risks through Standard Contractual Clauses. You may withdraw consent anytime via browser or cookie banner settings.

4. Use of Your Data

  • To manage communications and respond to inquiries.

  • To distribute newsletters if subscribed.

  • To improve our services, website functionality, and user experience.

  • To comply with legal or regulatory requirements.

5. Data Retention

We retain data only as long as necessary:

  • Technical/analytical data: up to 2 years (persistent cookies).

  • Contact and inquiry data: until purpose is fulfilled or 3 years after last contact.

  • Newsletter data: until unsubscribed or consent is withdrawn.

6. Data Sharing

Data may be shared with:

  • IT and hosting providers (e.g. web servers, analytics).

  • Legal advisors or authorities when legally required.

We ensure all processors are bound by data protection obligations.

7. Data Transfers

If data is transferred outside the EEA, we rely on appropriate safeguards such as Standard Contractual Clauses to ensure an adequate level of protection.

8. Your Rights

Under GDPR, you have the right to:

  • Access your personal data

  • Rectify inaccuracies

  • Delete data (“right to be forgotten”)

  • Restrict processing

  • Object to processing

  • Data portability

  • Withdraw consent at any time

  • File a complaint with the Austrian Data Protection Authority if you believe your rights are violated