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Privacy policy

The protection of your personal data is a matter of great importance to aws Fondsmanagement GmbH ("FMG", "we", "us"). Therefore, we comply with the applicable legal provisions for the protection, lawful handling, and confidentiality of personal data, as well as data security, particularly the Austrian Data Protection Act ("DSG"), the EU General Data Protection Regulation ("GDPR"), and the Telecommunications Act ("TKG").

This privacy policy informs you about the processing of your personal data by FMG and your related rights. The content and scope of data processing depend on the products you have requested.

1. Who is responsible for data processing, and who can you contact?

a. The data controller, in accordance with Article 4(7) of the GDPR, responsible for data processing is:

aws Fondsmanagement GmbH
Rechte Wienzeile 225
1120 Vienna
Phone: +43 1 501 75 ext. 721
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If you have concerns regarding the processing of your personal data or wish to exercise your rights, the data protection coordinator of the sole shareholder Austria Wirtschaftsservice GmbH also acts as the data protection coordinator for aws Fondsmanagement GmbH:

Dr Bettina Schober
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b. aws Fondsmanagement GmbH is a shareholder and management of aws Mittelstandsfonds Beteiligungs GmbH & Co KG, aws Gründerfonds Beteiligungs GmbH & Co KG and aws Gründungsfonds II Beteiligungs GmbH & Co KG.

The tasks ("measures") of the mentioned funds particularly include providing growth capital for founders and SMEs and mobilising private growth capital.

2. What data is processed, and from which sources does this data come?

We process the personal data you provide to us as part of the execution of one of the aforementioned measures, e.g., information about your company for the assessment of a potential investment. Additionally, we process data that we have lawfully obtained from publicly accessible sources (e.g., company register).

Personal data includes your details (name, address, contact details, etc.), data related to your project, such as project costs and financing, and information from your electronic communication with FMG (e.g., apps, cookies, etc.), as well as data for meeting legal and regulatory requirements.

3. For what purposes and on what legal basis is the data processed?

a. To fulfil contractual obligations (Art. 6(1)(b) GDPR):

The processing of personal data is for the purpose of preparing and executing an investment agreement based on the above-mentioned measure (see section 1.b). If no investment agreement is concluded, the data will be deleted unless there are other legitimate interests of FMG opposing deletion.

b. To protect legitimate interests (Art. 6(1)(f) GDPR):

Where necessary, personal data may be processed beyond the actual fulfilment of the contract to protect the legitimate interests of FMG or third parties, based on a balancing of interests.

c. Based on your consent (Art. 6(1)(a) GDPR):

If you have given us consent to process your personal data, the processing will only take place in accordance with the purposes outlined in the consent declaration and to the extent agreed. You may revoke your consent at any time with future effect (e.g., you can object to the processing of your personal data for marketing and advertising purposes if you no longer agree with such processing):

4. Who receives the data?

If there is a legal or regulatory obligation, public authorities and institutions (e.g., organs and representatives of the Court of Auditors) may be recipients of your personal data.

In addition, our commissioned processors (especially IT service providers, lawyers, and other advisors) receive your data, provided they need it to perform their respective service. All processors are contractually obliged to treat your data confidentially and only process it as part of the service provision.

5. How long is the data stored?

We process your personal data, where necessary, for the duration of the entire business relationship and beyond, in accordance with legal retention and documentation obligations, particularly as set out in the Commercial Code (UGB) and the Federal Fiscal Code (BAO), in their applicable versions. If we no longer need your personal data, we will delete it from our systems and records or anonymise it so that you can no longer be identified.

6. What data do we collect from visitors and users of our website?

When you use our website, we collect, gather, and store the following data:

We automatically collect this access data via cookies.

7. Does the website use cookies?

Cookies are small text files stored on your computer to recognise the user and their settings. We use cookies to optimise the content of the website and improve its usability.

A detailed pre-information about the use of individual cookies (type, duration of function, and any third-party access) as well as your consent before the start of data usage ("opt-in") is provided via the cookie banner on our website. Your consent can be changed or revoked at any time via this cookie banner. No consent is required for storing cookies if they are essential for providing the offered content or services.

8. Matomo

Our website uses Matomo, an open-source application/web analytics software for statistical analysis of user access. Matomo uses cookies. The information generated by the use of this website (cookies) is transferred to the aws web server and stored for usage analysis purposes. We anonymise the IP address before processing and storing. You can prevent the installation of cookies at any time by adjusting your browser settings. You can also prevent actions performed on the website from being analysed and linked.

More information about Matomo can be found on their website.

9. Newsletter

Based on your consent to receive our newsletter, we will use the personal data you voluntarily provide (salutation, title, first name, last name, email address) for sending our newsletter by email. You can revoke this consent at any time with future effect (e.g., via the unsubscribe link in each newsletter or by email).

After revocation, no further data will be collected, and your email address will be deleted from the distribution list.

We use the newsletter software of eyepin GmbH, Billrothstraße 52, 1190 Vienna, Austria.

The newsletters from eyepin GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows for statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, eyepin GmbH can detect whether and when an email was opened by an affected person. Furthermore, newsletter tracking collects which links contained in the email were clicked by the affected person.

Personal data collected via the tracking pixels in the newsletters and newsletter tracking is stored and evaluated by us to optimise the newsletter distribution and to better tailor the content of future newsletters to the interests of the affected person. These personal data are not passed on to third parties. Affected persons are entitled to withdraw their specific, separate consent declaration given via the double opt-in procedure by unsubscribing from the newsletter at any time. Further information on Eyepin can be found on their website.

10. Contact

If you contact us via the contact form on our website, by phone, or by email, we will store the personal data you provide (email, name, phone number, and your inquiry or related documents) and process them solely for the purpose of handling your inquiry and responding to you. In our contact form, mandatory fields are indicated, and other fields can be filled out voluntarily

11. How do we protect your data?

We comply with the provisions of Article 32 GDPR by implementing appropriate technical and organisational security measures, and we do our utmost to ensure the confidentiality and security of your personal data.

12. What data protection rights do individuals have?

a. Information, correction, deletion

Individuals have the right to (i) request confirmation from FMG as to whether personal data concerning them is being processed, and, if so, to obtain information about it, (ii) request the correction of incorrect personal data concerning them, and (iii) under certain conditions, request the deletion of personal data concerning them.

b. Objection

Furthermore, individuals have the right to object to the processing of their personal data. In the event of such an objection, FMG will no longer process the data, unless (i) it can demonstrate compelling legitimate grounds for processing that override the interests, rights, and freedoms of the individual, or (ii) the processing serves to establish, exercise, or defend legal claims.

c. Restriction of processing

Individuals also have the right to request the restriction of processing by FMG if (i) they contest the accuracy of the data concerning them, for a period that allows FMG to verify the accuracy, (ii) the processing is unlawful, and they oppose deletion and instead request restriction, (iii) FMG no longer needs the data for processing purposes, but they require the data for the establishment, exercise, or defence of legal claims, or (iv) they have objected to processing, and a decision on the underlying aspects is pending.

d. Portability

Under certain conditions, individuals may also request to receive the personal data they provided to FMG and request that FMG transmit these data directly to a third party.

13. Exercising your rights

To exercise these rights, please contact FMG or its data protection coordinator in writing (contact details can be found above in section 1). Of course, the data protection coordinator is also available for other inquiries regarding the use and security of your data at any time. If you believe that FMG has unlawfully used your data, you can also lodge a complaint with the Austrian Data Protection Authority.

14. Final provision

In the course of continuous development, FMG will continue to adapt this privacy policy. Therefore, you should regularly review this policy to stay informed about the current version.