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Data protection agreement

Data privacy policy of Unwired Networks GmbH.

1. Data Privacy Policy

The following statement describes to you as a visitor to the website, customer or prospective customer, and as a WiFi user, for which purpose which type of data is collected, for how long it is stored, and how you can control the handling of your personal data at any time. We therefore process your data exclusively on the basis of the statutory provisions (GDPR, TKG 2021). In this data privacy information we inform you about the most important aspects of data processing within the scope of our website and WiFi services.

1.1 Controller

Name/Company: Unwired Networks GmbH Street No.: Gonzagagasse 11/25 Postal code, city, country: 1010, Vienna, Austria Commercial register number: 365784v Managing Director: Mag. Alexander Szlezak Phone number: +43 1 996 2051 Contact: Contact form (data protection)

1.2 Data Protection Officer

For questions or suggestions regarding data protection, please contact our company data protection officer. Contact: Contact form (data protection)

2. Purpose of Processing

2.1 Processed Data

List of categories with examples:

  • Master data (e.g. names, addresses).
  • Contact data (e.g. e-mail, phone numbers).
  • Contract data (e.g. subject of contract, term, customer category).
  • Payment data (e.g. bank details, payment history).
  • Logs & website analytics (e.g. browser type & browser version, operating system, referrer, IP address).
  • Cookies (e.g. Google Ads, LinkedIn, session cookies, …).

Note: No special categories of data pursuant to Art. 9 (1) GDPR are processed.

Logs

Our website (web server, plugins) stores log data including IP addresses for a short period of time for the purpose of technical monitoring of the service and prevention of misuse.

Cookies

A “cookie” is a small file consisting of a text-only string of information that a website transfers to the web browser on your computer’s hard drive, where it is stored temporarily for the duration of your visit to the site, or sometimes longer, depending on the type of cookie. Cookies perform different functions, for example distinguishing you from other users of the same website or remembering certain facts about you, such as particular preferences, and are used by most websites to improve the user experience. Each cookie is unique to your web browser and contains anonymous information. A cookie usually contains the name of the domain it originated from, the “lifetime” of the cookie, and a value, usually in the form of a randomly generated, unique number. As we respect your right to privacy, you can decide not to allow certain types of cookies. Apart from technically necessary cookies, which may be set without your consent, you can therefore consent to or reject other cookies, such as performance cookies and cookies for marketing purposes, from the outset.

Cookies Not Requiring Consent

Where the use of cookies is strictly necessary from a technical point of view, e.g. for the correct display of the website, we use them. The following cookies may be used:

  • user-input cookies (session-id), e.g. first-party cookies that store user input, for instance when filling in online forms, limited to the duration of the session. Persistent cookies with a storage duration of a few hours may be exempt.
  • authentication cookies, which record the login status of the user, for example once logged in as a family member. This must be limited to the duration of the session.
  • user-centric security cookies, which serve to increase the security of a service, e.g. detection of repeated failed login attempts, for a limited period of a few hours.
  • multimedia content player cookies, which store technical data for the playback of video and audio files, for the duration of a session, whereby no additional information that is not strictly necessary for playback may be included.
  • load-balancing cookies, which are necessary with regard to the technology of a so-called load balancer to ensure forwarding to a specific server in the pool, limited to the duration of the session.
  • user-interface customization cookies, which store user preferences regarding a service across multiple websites and are not linked to other permanent identifiers, e.g. username, but are expressly requested, e.g. via button or checkbox, such as cookies for setting the language preference, for the duration of the session.
  • third-party social plug-in content-sharing cookies, provided you are a logged-in member of a social network and they are required for the desired functionality across third-party websites, for the duration of the browser session or until the member logs out. As a non-member or logged-out member, however, you must give your consent.
Cookies Requiring Consent – Cookie Banner

For cookies requiring consent, we obtain your consent in accordance with Section 165 (3) TKG 2021 via our cookie banner. Cookies and services requiring consent, e.g. statistics and marketing cookies (Google Ads, LinkedIn Insight Tag) or embedded content (YouTube videos), are only loaded after you have given your consent in the cookie banner. Without your consent, only technically necessary cookies are set. You can change or withdraw your selection at any time with effect for the future by opening “Edit cookie settings” on our website.

2.2 Data Subjects

  • Prospective customers
  • Customers
  • Suppliers, service providers, partner companies and their employees
  • Job applicants
  • Website visitors
  • Employees

2.3 Legal Basis

  • We process master data, e.g. names and addresses as well as contact data of users, applicant data, contract data, e.g. services used, names of contact persons, payment information, for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 (1) lit. b GDPR.
  • In order to be able to offer the website, Unwired collects technically strictly necessary data. In addition, Unwired has a legitimate interest in collecting further data for the optimization and security of the website. For the use of personal data, e.g. e-mail addresses, Unwired obtains the consent of the website user.
  • The legal basis for obtaining consent is Art. 6 (1) lit. a and Art. 7 GDPR; the legal basis for processing for the fulfilment of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 (1) lit. b GDPR; the legal basis for processing for the fulfilment of our legal obligations is Art. 6 (1) lit. c GDPR; and the legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR.
Legal Basis for Newsletter Dispatch
  • We inform existing employees, customers, suppliers and partners by newsletter within the meaning of the GDPR on the basis of our legitimate interest. We inform prospective customers by newsletter on the basis of their given consent within the meaning of the GDPR.
  • Germany: The dispatch of the newsletter and the measurement of its success are based on the recipients’ consent pursuant to Art. 6 (1) lit. a, Art. 7 GDPR in conjunction with Section 7 (2) No. 3 UWG, or on the basis of the statutory permission pursuant to Section 7 (3) UWG.
  • Austria: The dispatch of the newsletter and the measurement of its success are based on the recipients’ consent pursuant to Art. 6 (1) lit. a, Art. 7 GDPR in conjunction with Section 174 TKG 2021, or on the basis of the statutory permission pursuant to Section 174 (3) and (4) TKG 2021.
  • The logging of the registration process is based on our legitimate interests pursuant to Art. 6 (1) lit. f GDPR and serves as proof of consent to receive the newsletter.
  • Cancellation/withdrawal: You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent. You will find a link to cancel the newsletter at the end of each newsletter. If users have only registered for the newsletter and cancelled this registration, their personal data will be deleted.

2.4 Third-Party Providers

Within the EU

Data transfer within the company: We may pass on individual data processing operations to specialized areas of our company. This is done so that we can process your data more efficiently, e.g. for internal administrative purposes. External service providers: We comply with legal and contractual obligations. Data processing is often carried out by companies specialized in this field, so-called service providers. Our processors include in particular IT service providers, service providers in the context of customer support, contract management, market research institutes, marketing companies and advertising agencies. Courts and authorities: There are also legal obligations that we can only fulfil by transferring your personal data to authorities or courts to the extent required. Other recipients: Within the scope of the contractual relationship, and in particular in connection with our service obligations or in connection with legal disputes, further transfers of your personal data may occur depending on the individual case, such as to lawyers, professional representations, direct marketing companies, banks, insurance companies, auditors, tax advisors, external payment service providers.

Outside the EU

Data is only transferred to a third country if the European Commission has confirmed an adequate level of data protection for that third country (Art. 45 GDPR), for example in the case of US providers that hold an active certification under the EU-U.S. Data Privacy Framework, or if other suitable data protection guarantees are in place, in particular EU Standard Contractual Clauses including a documented case-by-case assessment of the adequacy of the level of protection (Art. 46 GDPR). With your explicit consent, data may be transferred to a third country pursuant to Art. 49 (1) lit. a GDPR. On our website we use various cookies and similar technologies through which personal data may also be processed by us and by third-party providers. In the case of a transfer to the USA without suitable guarantees, there is in particular the risk that your data may be subject to access by US authorities for control and surveillance purposes, without effective legal remedies being available. Before we set cookies requiring consent and transfer your data to these companies, we ask for your explicit consent via our cookie banner. You can withdraw your consent at any time with effect for the future by adjusting your preferences under “Edit cookie settings” on our website.

  • We use the invoicing software “Easybill” provided by easybill GmbH, Düsselstr. 21, 41564 Kaarst, Germany, on the basis of our legitimate interests. Further information: https://www.easybill.de/privacy
  • We use the CRM system “Pipedrive” provided by Pipedrive OÜ, Paldiski mnt 80, Tallinn, Harjumaa 10617, Estonia, on the basis of our legitimate interests. We also use Pipedrive to send our newsletter and measure its success. Further information: https://www.pipedrive.com/en/privacy
  • We transfer data to our account-holding bank for the purpose of processing payment orders, as well as to our tax advisor.
  • We use upstream service providers in order to be able to provide our services, e.g. A1 Telekom Austria AG, Hutchison Drei Austria GmbH.
  • We use shipping service providers for the dispatch of goods and documents, e.g. Österreichische Post AG, DHL Paket (Austria) GmbH.
  • We use the web-based instant messaging service “Slack” provided by Slack Technologies Limited (a Salesforce company), Salesforce Tower, 60 R801, North Dock, Dublin, Ireland, on the basis of our legitimate interests. Further information: https://slack.com/trust/privacy/privacy-policy
  • To integrate different databases and tools, we use Zapier, a service of Zapier Inc., San Francisco, California, USA. Zapier is certified under the EU-U.S. Data Privacy Framework. Further information: https://zapier.com/privacy
  • We use “Google Workspace” provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as our document management system and e-mail provider on the basis of our legitimate interests. Further information: https://policies.google.com/privacy
  • We use the cloud services of Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, among other things for sending e-mails from our website forms and systems. Further information: https://aws.amazon.com/privacy/
  • We use the services of Easy Software Ltd., 124 City Road, London EC1V 2NX, United Kingdom (Easy Redmine), for the processing of project-related tasks and support requests. Further information: https://www.easyredmine.com/contacts/gdpr-compliance
Website

In order to be able to offer the website, Unwired works with various service providers and partners, e.g. roaming partners, who may also be given access to the technical systems and data for troubleshooting purposes. Some of these service providers and partners are located outside the European Union. Where this is the case, Unwired ensures by means of suitable guarantees that the high level of data protection of the European Union and of Austria is also maintained by these service providers and partners.

  • This website uses Borlabs Cookie provided by Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany, which sets a technically necessary cookie to store your cookie consents. Borlabs Cookie does not process any personal data. The borlabs-cookie stores the consents you gave when entering the website. If you wish to withdraw these consents, use “Edit cookie settings” or simply delete the cookie in your browser. When you re-enter or reload the website, you will be asked for your cookie consent again.
  • This website uses WPML. It is used for the purpose of translating the website. WPML also stores your current browser language in order to display the website in the correct language.
  • To protect our website against attacks and misuse, we use the security plugin Wordfence (Defiant Inc., USA) on the basis of our legitimate interests. IP addresses and access data are processed in this context. Further information: https://www.wordfence.com/privacy-policy/
  • For contact and inquiry forms we use Fluent Forms. The data you enter is processed on our systems and used exclusively to handle your inquiry. To protect against automated misuse, we use the consent-free, locally operated captcha mechanism ALTCHA; no data is transferred to third parties in this process.
  • On this website we use the analytics software “Matomo” (InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand) in a self-hosted setup. Further information: https://www.matomo.org
    • the user’s IP address, truncated by the last two bytes (anonymized)
    • the subpage accessed and the time of access
    • the page from which the user reached our website (referrer)
    • which browser with which plugins, which operating system and which screen resolution is used
    • the time spent on the website
    • the pages accessed from the subpage visited
    • The data collected with Matomo is stored on our own servers. It is not passed on to third parties.
  • We use the “Google Tag Manager” (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to integrate and manage analytics and marketing services on our website. The Google Tag Manager itself does not set cookies and does not process any personal data beyond its technical delivery function.
  • Google Ads and Google Conversion Tracking
    • We use Google Ads, an online advertising program of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, including conversion tracking, to measure the success of our advertisements.
    • The associated cookies are only set after you have given your consent via our cookie banner. You can withdraw your consent at any time under “Edit cookie settings”.
    • More information on Google Ads and Google Conversion Tracking can be found in Google’s privacy policy: https://policies.google.com/privacy
  • LinkedIn (Insight Tag): We use the LinkedIn Insight Tag of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, for conversion tracking on our website. The tag is only loaded after you have given your consent via the cookie banner.
  • On individual pages we embed videos from YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). When a video is played, data, including your IP address, is transferred to YouTube. The embedding only takes place after you have given your consent via the cookie banner. Further information: https://policies.google.com/privacy
  • For interactive product demos we use Storylane (Storylane Inc., San Francisco, USA). When you start a demo, usage data, including your IP address, is processed by Storylane; the transfer is based on EU Standard Contractual Clauses. Further information: https://www.storylane.io/privacy-policy
  • For online appointment booking we use meetergo (meetergo GmbH, Germany). When you book an appointment, the data you enter (name, e-mail address, selected time slot) is processed by meetergo. Further information: https://www.meetergo.com/datenschutz
  • To answer questions on our website, we use a chatbot that uses the API of Anthropic (Anthropic, PBC, San Francisco, USA) to generate responses. Your chat input is transferred to Anthropic for this purpose; the transfer is based on EU Standard Contractual Clauses. Please do not enter any personal data in the chat that is not required for your inquiry. Further information: https://www.anthropic.com/legal/privacy
  • For profile pictures in blog posts we use Gravatar (Automattic Inc., USA). When the page is loaded, your IP address is transferred to Gravatar. Automattic is certified under the EU-U.S. Data Privacy Framework. Further information: https://automattic.com/privacy/
Newsletter

Dispatch service provider: Our newsletters are sent via our CRM system “Pipedrive” provided by Pipedrive OÜ, Paldiski mnt 80, Tallinn, Harjumaa 10617, Estonia. The data of newsletter recipients (e.g. e-mail address, opening and click behaviour for success measurement) is processed in Pipedrive for this purpose. The provider’s privacy policy can be viewed here: https://www.pipedrive.com/en/privacy

2.5 Retention Periods

We do not store collected data longer than necessary and are guided by our legal obligations.

  • We delete inquiries once they are no longer required. We review this requirement every two years. Inquiries from customers who have a customer account are stored permanently; for deletion, please refer to the information on the customer account.
  • The statutory limitation period under the Austrian General Civil Code (ABGB) is between three and thirty years.
  • In the case of statutory archiving obligations, deletion takes place after their expiry.
  • Receipts, business papers and other documents pursuant to Section 212 UGB: 7 years pursuant to Section 132 BAO.
  • Application data: 6 months after rejection pursuant to Section 15 GlBG.
  • The newsletter subscription can be cancelled by the data subject at any time. For this purpose, a corresponding link can be found in each newsletter.
  • This also enables the withdrawal of consent to the storage of the personal data collected during the registration process.

3. Applicable Legal Bases

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not stated in the data privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) lit. a and Art. 7 GDPR; the legal basis for processing for the fulfilment of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 (1) lit. b GDPR; the legal basis for processing for the fulfilment of our legal obligations is Art. 6 (1) lit. c GDPR; and the legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.

3.1 Changes and Updates to the Data Privacy Policy

We ask you to inform yourself regularly about the content of our data privacy policy. We adapt the data privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation, e.g. consent, or other individual notification.

3.2 Provision of Contractual Services

We process master data, e.g. names and addresses as well as contact data of users, contract data, e.g. services used, names of contact persons, payment information, for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 (1) lit. b GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.

3.3 Rights of Data Subjects

You have in principle the rights to information, rectification, erasure, restriction, data portability, withdrawal and objection. If you believe that the processing of your data violates data protection law or that your data protection rights have otherwise been infringed in any way, you can lodge a complaint with the supervisory authority. In Austria, this is the Data Protection Authority (Datenschutzbehörde). You have the right to request confirmation as to whether the data in question is being processed, and to information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR. In accordance with Art. 16 GDPR, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you. In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted without undue delay, or alternatively, in accordance with Art. 18 GDPR, to request a restriction of the processing of the data. You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers. You also have the right, pursuant to Art. 77 GDPR, to lodge a complaint with the competent supervisory authority. You have the right at any time to obtain, free of charge, information about the data stored concerning your person, its origin and recipients, and the purpose of the data processing. You also have the right to data portability and the erasure of your data. Please contact us via the contact form or by phone. Should there ever be cause for complaint regarding the processing of your data, you can also contact the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna, or dsb@dsb.gv.at at any time.

3.3.1 Right of Withdrawal

You have the right to withdraw consent given pursuant to Art. 7 (3) GDPR with effect for the future.

3.3.2 Right to Object

You may object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may in particular be made against processing for the purposes of direct marketing.

3.3.3 Erasure of Data

The data processed by us is erased or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated within the scope of this data privacy policy, the data stored by us is erased as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent its erasure. If the data is not erased because it is required for other legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons. Germany: In accordance with statutory requirements, retention takes place in particular for 6 years pursuant to Section 257 (1) HGB and for 10 years pursuant to Section 147 (1) AO. Austria: The statutory limitation period under the Austrian General Civil Code (ABGB) is between three and thirty years. In accordance with statutory requirements, retention takes place in particular for 7 years pursuant to Section 132 (1) BAO, for 22 years in connection with real estate, and for 10 years for documents in connection with electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop is used.

3.4 Data Security

We endeavour to protect our users against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data. In particular:

  • we encrypt many of our services using SSL.
  • we review our practices for the collection, storage and processing of data, including physical security measures, to protect against unauthorized access to systems.
  • we restrict access to personal data to employees and contractors who strictly need to know this data in order to process it for us and who are subject to strict confidentiality obligations.

3.5 Scope of the Data Privacy Policy

Our data privacy policy applies to all services offered by Unwired Networks GmbH. Our data privacy policy does not apply to services offered by other companies or individuals, including products or websites that may be displayed to you in search results, or other websites linked from our services. Our data privacy policy does not cover the handling of information by other companies or organizations that advertise our services and that may use cookies, pixel tags and other technologies to provide and offer relevant advertising.

3.6 Compliance in Cooperation with Government Authorities

We regularly review our compliance with our data privacy policy. When we receive formal written complaints, we will contact the person who submitted the complaint for the purpose of processing it. We cooperate with the competent regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Competent Data Protection Authority

Österreichische Datenschutzbehörde (Austrian Data Protection Authority) Barichgasse 40-42 1030 Vienna Phone: +43 1 521 52-25 69 E-mail: dsb@dsb.gv.at Last updated: 21 July 2026

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