Privacy Policy

Effective: July 2023

1. General Information

Neworn GmbH, Spitalgasse 27/13, 1090 Vienna ("Neworn", "we", "us") places great importance on protecting your personal data. We are committed to complying with applicable data protection laws, in particular the General Data Protection Regulation (GDPR), the Austrian Data Protection Act (DSG), and the Telecommunications Act (TKG).This Privacy Policy provides information about the nature, scope, and purposes of the collection and processing of your personal data in connection with your use of our website and mobile app.

Controller Details:
Name: Neworn GmbH
Address: Spitalgasse 27/13, 1090 Vienna, Austria
Phone: +43 664 4846256
Email: info@neworn.com

‍2. What Are Personal Data?
Personal data are any information relating to an identified or identifiable natural person (data subject). A person is considered identifiable if they can be directly or indirectly identified, particularly by reference to identifiers such as name, email address, or IP address.

3. What Data Do We Collect from Visitors and Users of Our Website?

Contact Us
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If you contact us using the contact details provided above or through the contact form on our website (https://neworn.com), we process your personal data—such as your name, email address, and/or phone number, as well as the content of your inquiry—for the purpose of responding to and handling your request. The legal basis for this data processing is:
- The performance of (pre-)contractual obligations pursuant to Article 6(1)(b) GDPR, or
- Our legitimate interest in efficiently responding to inquiries in accordance with Article 6(1)(f) GDPR.

Newsletter
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If you have subscribed to our newsletter about our services and partner offers, we will process your email address and the newsletter open rates. You can find a list of our partner companies here.
This processing is based on your voluntary and explicit consent in accordance with Article 6(1)(a) GDPR in conjunction with § 174 of the Telecommunications Act (TKG). You may withdraw your consent at any time with future effect (e.g., via email or by clicking the unsubscribe link provided in every newsletter).
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Social Media
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You can interact with us on our social media pages by commenting on our posts, reacting to them (e.g., using the “Like” button), sharing them, or sending them to other users. In doing so, we process your interactions, your username, and, if applicable, personal data of third parties you mention or tag.Please note: The platforms themselves may also process this data. In this case, the respective platform and Neworn act as joint controllers pursuant to Article 26 GDPR.
Further information on data processing by these platforms can be found here:
‍Facebook
‍Instagram
‍Pinterest
‍TikTok
‍LinkedIn
‍We process this data to respond to your questions, to provide you with a platform for expression, to engage with your feedback, and to promote our offerings. The legal basis for this processing is either our and your legitimate interests pursuant to Article 6(1)(f) GDPR or the fulfillment of our (pre-)contractual obligations pursuant to Article 6(1)(b) GDPR.Usage DataWhen you visit our website, we automatically process the following data:IP addressInformation about your deviceReferrer URLName and version of your web browserSession IDLog filesDate and time of your visit to a (sub)pageInteraction data (e.g., number of visits, session duration)These data are transmitted by your browser when accessing our site. We use them solely for the purpose of:
providing the website,
improving our services,
ensuring data security, and
enhancing user experience.
This data processing is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, including system usage logging, user rights management, and server log analysis for troubleshooting.

Cookies
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Cookies are small text files stored on your device when you visit a website, provided your browser settings allow it. These files store domain-specific information that can later be retrieved. Cookies enable our website to store essential data, provide you with our services, and improve your browsing experience. Some cookies remain stored on your device until you delete them or they expire. They help us recognize your browser on your next visit.
There are cookies that require your consent before being stored, and others that can be placed without consent because they are strictly necessary for the provision of our services.

Legal basis for cookie use:
The processing of personal data in connection with cookies and similar tracking technologies is based on your voluntary consent in accordance with Art. 6(1)(a) GDPR and relevant national regulations implementing the ePrivacy Directive (2002/58/EC).
Depending on your location, additional national laws may apply:
Austria: § 165(3) TKG
Germany: § 25(1) TTDSG
Other EU countries: their respective national laws

You may withdraw or change your consent at any time via:
the cookie banner on our website
app settings or browser/device settings

Types of cookies used:
(a) Essential cookies: Required to display and operate our website properly. Data is processed to ensure data security and prevent misuse. Legal basis: Art. 6(1)(f) GDPR in conjunction with § 165(3) TKG.
(b) Preference cookies: Allow the website to remember user preferences such as language or region. Legal basis: Art. 6(1)(a) GDPR in conjunction with § 165(3) TKG.
(c) Analytics cookies: Help us count visitors and analyze their behavior to improve functionality. Legal basis: Art. 6(1)(a) GDPR in conjunction with § 165(3) TKG.
(d) Marketing cookies: Used to track users across websites to display relevant and engaging ads. Legal basis: Art. 6(1)(a) GDPR in conjunction with § 165(3) TKG.

A full list of cookies can be found in the cookie banner under "Details." The banner appears automatically on your first visit to our site. You can also access it via the "Cookies" link in the footer.
If your settings include third-party providers who transfer data to countries without an EU adequacy decision (Art. 45 GDPR) or without suitable safeguards (Art. 46 GDPR), your consent will also apply to these transfers. Please note that your data may be subject to access by authorities in those third countries without effective legal remedies.You may modify your consent anytime by clicking "Allow all," "Decline," or adjusting individual preferences using the toggles and "Allow selection" button in the cookie settings.
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Cookies and Tools We Use
Google Tag Manager
We use the Google Tag Manager from Google Ireland Limited (Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland) to manage tags via an interface and to embed them into our website. Tags are small tracking codes and code fragments that allow us to measure traffic and user behavior, assess the effectiveness of advertising activities, set up targeting, and test our website. Google Tag Manager does not store any cookies in your browser. Instead, it manages the tags of various tracking tools.

Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland). When you interact with our website, Google Analytics collects the following data: the URL of the pages you visit, information about your device, the browser you use, your operating system, the time of page access and duration of your visit, data about your user behavior (e.g., navigation), your approximate location, your conversion events (e.g., purchases and registrations), and your traffic sources. Google also holds a Privacy Shield certification, thereby ensuring a higher level of data protection. More information on data processing: https://policies.google.com/privacy?hl=en and https://support.google.com/analytics/answer/6004245?hl=en

‍Adjust
We use Adjust, an analytics service provided by Adjust GmbH (Saarbrücker Straße 37A, 10405 Berlin, Germany), to analyze user behavior and subsequently optimize our services and advertising efforts. When you interact with our apps, Adjust collects the following data: information about your device and operating system, the time and duration of your visit, information about your user behavior, your approximate location, your conversion events (e.g., purchases, registrations), and your traffic sources. More information: https://www.adjust.com/terms/privacy-policy/

‍Google Ads
We use the conversion tracking (visitor action evaluation) of the online advertising program "Google Ads" from Google Ireland Limited (Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland). When you click on a Google ad, a cookie is placed on your device for conversion tracking. The information gathered via this cookie is used to generate conversion statistics. Additionally, we use the retargeting feature of Google Analytics by creating audiences based on our user data in Google Analytics and sharing them with Google Ads. We also use the "Customer Match" feature of Google Ads to create custom audiences. This allows us to show personalized ads within the Google ad network. More information: https://policies.google.com/privacy?hl=en

‍Google Optimize
We use Google Optimize, a website optimization service provided by Google Ireland Limited (Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland). This service allows us to optimize our website by displaying specific content and features to a selected group of users and evaluating the changes statistically. Google Optimize sets specific cookies (_gaexp and _opt_expid) to recognize the tests. More information: https://policies.google.com/privacy?hl=en and https://support.google.com/optimize/answer/7012154#zippy=%2Cthemen-in-diesem-artikel

‍Meta Ads (including Custom Audiences)
We use the Meta Pixel for conversion measurement of Meta Ads, the advertising platform of Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). The Meta ad network includes Facebook, Instagram, WhatsApp, and the Meta Audience Network. Using the "Custom Audiences" feature, we can track whether you were redirected to our website by clicking on a Meta ad. This allows us to evaluate the effectiveness of ads for statistical and marketing purposes and to optimize our advertising efforts. More information: https://www.facebook.com/privacy/policy

‍Microsoft Advertising
We use website conversion tracking via "universal event tracking" (UET) from Microsoft Advertising, the advertising platform of Microsoft Ireland Operations Limited (One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). This allows us to analyze the behavior of users who land on our website through our ads in the Microsoft ad network and optimize our services and marketing measures. Microsoft Advertising uses its own cookies to distinguish individual users (_uetvid), individual sessions (_uetsid), and to optimize conversion tracking accuracy (_uetmsclkid). More information: https://privacy.microsoft.com/privacystatement

‍Hotjar
We use Hotjar, a web analytics service by Hotjar Limited (Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta), to statistically evaluate user behavior on our website using heatmaps and session recordings and to further optimize our website. The cookies hjSessionUser and hjSession are set. More information: https://www.hotjar.com/legal/policies/privacy/

‍Cookiebot
We use Cookiebot, the consent management platform of Cybot A/S (Havnegade 39, 1058 Copenhagen, Denmark), to obtain and store your data protection consent before collecting and further processing your data using cookies and tracking technologies. More information: https://www.cookiebot.com/de/privacy-policy/

‍HubSpotWe use the services of HubSpot (2nd Floor 30 North Wall Quay, Dublin 1, Ireland) on our website. HubSpot helps us collect data on your visitor behavior for statistical purposes. More information: https://legal.hubspot.com/privacy-policy

‍Gleap
To provide our services efficiently, Neworn (the “data controller”) works with selected external sub-processors. One of these sub-processors is Gleap, a company specializing in building effective help centers. Gleap processes personal data on behalf of the data controller according to the terms of the Data Processing Agreement (DPA) concluded between Neworn and Gleap.
Gleap’s role as a sub-processor primarily involves responding to user inquiries.Gleap commits to implementing and maintaining appropriate technical and organizational measures to ensure the security and confidentiality of processed personal data. In case of changes to the sub-processors commissioned by Neworn, the data controller will be notified in accordance with GDPR requirements.The data controller confirms and agrees that it has conducted a proper assessment of Gleap’s data processing activities and is convinced of Gleap’s ability to comply with the requirements of the General Data Protection Regulation (GDPR).
By accepting this data processing agreement, the data controller consents to the appointment of Gleap as a sub-processor for the purposes described herein.
More information: https://www.gleap.io/privacy-policy

‍Job Applications
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We are always looking for highly motivated individuals who are passionate about sustainability. If you apply for an open position with us, we process the applicant data you provide (e.g., name, address, email address, phone number, date of birth, and data from your resume). This includes our correspondence with you. We process this data to evaluate your application and for personnel selection in filling open positions. The data processing is thus carried out for the initiation of an employment relationship based on pre-contractual measures in accordance with Art. 6 para. 1 lit. b GDPR.


4. Data We Collect from Visitors and Users of Our App
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Registration and Account
When you register to use the app, we process your name and username, your phone number, email address, postal code, and optionally your gender. In addition, we offer a filter function in the app that allows you to receive results and recommendations tailored to your child. To use this feature, you can add your child to your profile under "Add Children." In this case, we process your child’s name, date of birth, and optionally their gender. We use this data solely to filter the results according to your preferences. Providing information about your child is not required to use the app, but it is necessary if you wish to use the filter function.Furthermore, we process data about the products you offer or have purchased, the products you have marked as “Favorites,” and the users you follow in the app. We may also send you notifications through the app regarding products you’ve subscribed to and offers from users you follow. We collect and process this data to provide you with access to our app and services. The legal basis for this processing is Art. 6 para. 1 lit. b GDPR.If you have given your consent, we may send you surveys in the form of in-app notifications regarding our services. In doing so, we process your account data as well as the voluntary feedback you provide. The data is processed solely on the basis of your explicit and voluntary consent pursuant to Art. 6 para. 1 lit. a GDPR.

Usage Data
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While using our app, we collect the following personal data from you: IP address of your device, language, operating system, screen resolution, and usage behavior data. We collect and process this data based on our and your legitimate interests in ensuring security and further developing and improving the user-friendliness of our app. This data processing is therefore based on legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR.

Customer Service / Help Center
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If you contact our Help Center, we process your contact details as well as the content of your messages and communications. The legal basis is the fulfillment of our (pre-)contractual obligations pursuant to Art. 6 para. 1 lit. b GDPR and our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in the prompt handling of and response to any inquiries.

5. Recipients of Personal Data
We handle your personal data confidentially. Therefore, we deliberately keep the circle of recipients small.To operate our website and app, we use IT service providers who may also have access to personal data to the extent necessary to provide their services. These processors act on our behalf, based on our instructions, and only for the purposes stated above. If you provide personal data in connection with Neworn, Stripe also receives this data and processes it in accordance with Stripe’s privacy policy: https://stripe.com/en/privacy
‍In individual cases, we may also transfer your personal data to the following recipients to the extent necessary:
External third parties based on our legitimate interests (e.g., auditors, debt collection agencies, insurers in the event of a claim, legal representatives, etc.);
Authorities and public bodies to the extent required by law (e.g., tax authorities, data protection authorities, etc.).
We will not transfer your personal data to any other third parties for their own purposes without your consent. If personal data is transferred to recipients in third countries outside the EU and no adequacy decision by the EU Commission exists for the respective country pursuant to Art. 45 GDPR, the transfer takes place on a case-by-case basis subject to appropriate safeguards in accordance with Art. 46 GDPR or, where applicable, based on consent for specific purposes.6. Retention PeriodWe generally store your personal data only for as long as we need it to fulfill the purposes outlined above. When we no longer need your personal data, we delete it from our systems or anonymize it so that you can no longer be identified.We store your data collected through contact forms for a period of six months in order to respond to follow-up questions appropriately. A longer retention period only applies if it results from a subsequent business relationship, legal retention requirements, or the need to defend against legal claims.We process your personal data for newsletter subscriptions until you revoke your voluntary consent, but no longer than three years after the last contact with us.We store your usage data when visiting the website and app for a period of one year.We process your registration and account data as long as you maintain an active account with us or until you request deletion.Cookies can be divided into two categories based on their storage duration: session cookies and persistent cookies. Session cookies are automatically deleted when you leave our website. Persistent cookies remain stored on your device until they reach a set expiration date or are manually deleted by you in your browser. We use such cookies to recognize you on subsequent visits. In most cases, we store them for a few days. A longer storage period is only used if necessary to ensure an optimal and user-friendly website experience. Data from cookies that require consent is stored until you revoke your consent, provided the revocation occurs before the cookie's expiration.If your job application is not successful, we will retain your data for six months after the conclusion of the unsuccessful application process to (i) defend against potential claims under the Equal Treatment Act (GlBG) and (ii) for any further communication in connection with your application. The data processing is based on your and our legitimate interests in appropriate staffing. The legal basis is Art. 6 para. 1 lit. f GDPR. After this retention period, your personal data will be deleted.If we wish to keep your applicant data on record for up to three years, this will only be done on the basis of your explicit and voluntary consent pursuant to Art. 6 para. 1 lit. a GDPR. You can revoke this consent at any time with effect for the future without stating reasons. In the event of a successful application, the data collected will be stored until the end of the employment relationship and as long as statutory retention periods or potential legal claims exist.

7. Data Security
We do everything possible to ensure that visiting and using our website is as secure as possible. We comply with the provisions of Art. 32 GDPR to ensure the confidentiality and security of your personal data and implement appropriate technical and organizational security measures.

8. Data Subject Rights
You have the right to access the personal data we process about you. In addition, you have the right to rectify inaccurate data and delete your data ("right to be forgotten"). You may also have the right to restrict the processing of your data and the right to receive the data you have provided in a structured, commonly used, and machine-readable format ("data portability"). You can also revoke any consent you have given at any time with effect for the future. Furthermore, you have the right to object to the processing of your data at any time if there are grounds relating to your particular situation.You also have the right to lodge a complaint with the competent supervisory authority.
In Austria, this is:
Austrian Data Protection AuthorityBarichgasse 40-42, 1030 ViennaEmail: dsb@dsb.gv.atBefore submitting a formal complaint or if you have any questions about your personal data, please feel free to contact us at info@neworn.com.

9. Final Provisions
As we continue to develop our offering, we will regularly update this privacy policy. We will make the currently valid version of the privacy policy available on our website. We recommend that you check regularly for updates.