Privacy Policy

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation; “GDPR”), the controller must inform data subjects about the processing of personal data. With this document, we inform you about the personal data we process.

Definitions

For a better understanding of this privacy policy, you will find a brief explanation of the terms used below.

• Personal data (“data”): All data containing information about the personal or material circumstances of natural persons, for example name, address, email address, telephone number, date of birth, age, gender, social security number, video recordings, photos, etc. Data of legal entities are not subject to the provisions of the GDPR.
• Processing: Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• Recipient: A natural or legal person, public authority, agency or other body to which personal data are disclosed, whether a third party or not.

Our Contact Details

Should you have any further questions, we, as the controller of the data processing described herein, are at your disposal under the following contact details:

İYİGÜN A.Ş.

Yasin Iyiguen

Hauptstrasse 33B

CH-8272 Ermatingen, Switzerland

Tel.: +41 79 918 18 18

Email: info@waxol.ch

Purposes and Legal Basis of Processing

Data may only be processed for a specific purpose and only if the processing can be based on a corresponding legal basis. Processing may be justified for the following reasons:

We process your data for the following purposes on the basis of the following legal bases:

Recipients

Recipients support us in complying with statutory or legal obligations, in initiating and performing contracts, in services that require your consent, or in carrying out processing operations that are in our legitimate interest. We transmit or disclose the data in part, in particular, to the following recipients (processors or controllers):

We only transmit your data to other recipients if you have given your express consent pursuant to Art 6 (1) lit a GDPR, if this is legally permissible and necessary pursuant to Art 6 (1) lit b GDPR for the performance of a contractual relationship with you, if we are subject to a legal obligation pursuant to Art 6 (1) lit c GDPR, or if the disclosure is necessary pursuant to Art 6 (1) lit f GDPR to safeguard our legitimate interests and to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data.

We intend to transfer the data to the following third countries: United States of America.

An adequacy decision of the European Commission exists for the United States of America. By decision of 10 July 2023 on C(2023) 4745 final (available here), the European Commission decided that the United States of America provides an adequate level of data protection within the meaning of Art 45 GDPR if our contractual partner is entered in the list of the EU/US Data Privacy Framework (available here). Information on the registration of the individual providers in this list can be found in the respective section of this privacy policy.

If no adequacy decision exists, we may only transfer data on the basis of appropriate safeguards, such as standard contractual clauses, binding corporate rules, approved codes of conduct, approved certification mechanisms, etc. Under the conditions of Art 49 GDPR, a transfer may nevertheless be permissible. A copy of these safeguards for your particular case is available from us on request.

There is no intention to transfer the data to an international organisation.

Storage Period

Data is generally only stored for as long as is necessary due to statutory retention obligations. In addition, data may be stored if this is necessary to enforce or defend against third-party claims. Important retention periods can be found below:

Web Hosting and Third-Party Providers

Vercel

We use the cloud platform Vercel for hosting and providing our website. The provider is Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA (hereinafter: Vercel).

• Type of data: IP address, request headers and log data.
• Purpose: Fast delivery of the website via a global network (CDN) and protection against DDoS attacks.
• Legal basis: Art 6 (1) lit f GDPR (legitimate interest in a high-performance and secure web infrastructure).
• Data transfer: Vercel is certified under the EU-U.S. Data Privacy Framework. The transfer to the USA therefore takes place on the basis of an adequacy decision of the EU Commission.
• Further information: Further details can be found in the privacy policy available here.

Calendly

We use the Calendly tool on our website to arrange appointments. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, GA 30363, USA (hereinafter: Calendly).

• Type of data: Name, email address, IP address as well as information on the desired appointment (date, time, reason for the appointment) and, if applicable, further information provided by you in the booking form.
• Purpose: Enabling uncomplicated, fast and automated online appointment booking.
• Legal basis: If the appointment is made in the context of initiating or performing a contract, the legal basis is Art 6 (1) lit b GDPR. In all other cases, we have a legitimate interest in efficient appointment organisation and a user-friendly design of our processes (Art 6 (1) lit f GDPR).
• Data transfer: Calendly is certified under the EU-U.S. Data Privacy Framework. The data transfer to the USA is therefore secured by an adequacy decision of the EU Commission. In addition, Calendly uses standard contractual clauses.
• Further information: Further details can be found in the privacy policy available here.

TidyCal

For the provision of an online appointment booking function, we use the services of the provider TidyCal, AppSumo, 1305 E. 6th St. Suite 3, Austin, TX 78702, USA.

For the transfer of data to the USA, we have concluded standard contractual clauses of the European Commission with the provider, which ensure compliance with the European level of data protection. Further information on TidyCal and data protection at TidyCal can be found in the privacy policy available here.

Google Services

General

The provider of the following services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. Google’s privacy policy available here can be found at this link.

However, some services (such as Google Search or Google Maps) are provided by or transferred to the following company: Google LLC, 1600 Amphitheatre Pkwy, Mountain View, California 94043-1351, USA. Google LLC is domiciled in a third country. Google LLC is entered in the list, so that the data transfer to the USA is compliant with data protection law within the meaning of Art 45 GDPR. Further information on the certification of Google LLC can be found in the overview available here.

Some Google services use cookies. An overview of the cookies used, their purpose and storage period can be found in the cookie section of this privacy policy. For the use of Google services and the setting of the cookies required for this, your consent within the meaning of Art 6 (1) lit a GDPR or § 165 (3) TKG (Austrian Telecommunications Act) is obtained before processing. Your consent can be freely revoked at any time.

Prior consent is only not obtained for cookies if their sole purpose is the transmission of a message or if this is strictly necessary so that we can provide you with a service that you have expressly requested.

Google Ads

We use Google Ads (formerly Google AdWords) as an online marketing measure to promote our products and services. Google Ads is used to better analyse user actions. If you click on one of our Google Ads, the “Conversion” cookie is stored on your device by a Google domain. We also use Google Ad Remarketing for our website.

The most important cookies used in this context are:

Google Tag Manager

We use Google Tag Manager as an organisational tool with which we can manage website tags centrally and via a user interface. Tags are used, for example, to record your activities on our website. The tags mostly come from Google products such as Google Ads or Google Analytics.

Google Tag Manager does not set any cookies and does not store any data. Rather, it acts as a manager of the tags implemented in the system. The data is collected by the tags of the web analysis tools. In this sense, the data is passed through to the individual tracking tools and not stored.

Meta Services

Meta Business Tools

Within our online offering, we use Meta Business Tools, which are operated and provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”). The following processing operations take place exclusively on the basis of your express consent pursuant to Art 6 (1) lit a GDPR.

Meta Pixel

Meta Pixel is a code that loads a collection of functions with which Meta can track user actions on our website. The Meta Pixel can store your actions on our website in one or more cookies. Further information on the Meta Pixel can be found in the documentation available here. We also use Custom Audiences. Further information on this can be found in the legal documentation available here.

The pixel collects information such as your IP address and user ID and compares it with the data of your Facebook account.

Meta uses different cookies depending on interaction and user behaviour. The following cookies are used as examples:

LinkedIn Insight Tag

We use the LinkedIn Insight Tag for our website. The service provider is the American company LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For data protection-relevant aspects in the European Economic Area (EEA), the EU and Switzerland, LinkedIn Ireland Unlimited (Wilton Place, Dublin 2, Ireland) is responsible.

By embedding the tracking tool, data can be sent to LinkedIn, stored and processed there. This is a JavaScript code that we have integrated into our website. This function helps us to better adapt our advertising offering to your interests and needs.

Information on the standard contractual clauses at LinkedIn can be found in the documentation available here or at this link. You can find out more about the LinkedIn Insight Tag in the help section available here. You can also find out more about the data processed through the use of the LinkedIn Insight Tag in the privacy policy available here.

Cookies

Cookies are text files that are stored on your device in order to recognise it. Cookies may contain information about the use of our offers and services. Due to the ECJ ruling Planet49 GmbH, consent is also obtained for cookies if the cookies are not personal.

Some of the cookies used are only stored until you close our offer again (session cookies), whereas certain cookies are stored for a longer period and you can be recognised (persistent cookies). Some cookies are strictly necessary for the functioning of the website (essential cookies), others record visits and the origin of the visitor and measure this data without the cookies being able to establish a link to your person (performance cookies). Certain cookies are used for marketing purposes (marketing cookies). (Details can be found in the ECJ legal basis available here.)

Insofar as personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art 6 (1) lit b GDPR either for the performance of the contract, in accordance with Art 6 (1) lit a GDPR in the case of consent given, or in accordance with Art 6 (1) lit f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the user experience.

Via the cookie notice when you first visit the website, you can select which cookies you want to allow. Your consent is required for marketing cookies. If you wish to revoke your consent or change your cookie settings, you can make this change directly in your browser.

Your Rights

Right of access

You have the right to request confirmation as to whether personal data is being processed; if this is the case, you have a right of access to this personal data. This includes the following information: the purposes of processing; the categories of personal data; the recipients or categories of recipients; if possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria for determining this period; the existence of a right to rectification or erasure of the personal data concerned or to restriction of processing by the controller or a right to object to such processing; the existence of a right to lodge a complaint with a supervisory authority; all available information on the origin of the data; the existence of automated decision-making, including profiling.

Right to rectification

You have the right to request from the controller the rectification of inaccurate personal data and the completion of incomplete personal data.

Right to erasure

You have the right to request from the controller that personal data be erased without undue delay if one of the following reasons applies: The personal data is no longer necessary for the purposes for which it was collected. You revoke your consent on which the processing was based and there is no other legal basis for the processing. You object to the processing (Art 21 (1) GDPR) and there are no legitimate grounds for the processing, or you object to the processing pursuant to Art 21 (2) GDPR. The personal data has been processed unlawfully. The erasure of the personal data is necessary to fulfil a legal obligation. The personal data was collected in relation to information society services offered pursuant to Article 8 (1).

The right to erasure does not exist insofar as the processing is necessary to exercise the right to freedom of expression and information; to fulfil a legal obligation, to perform a task carried out in the public interest; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes for the assertion, exercise or defence of legal claims.

Right to restriction of processing

You have the right to request the restriction of processing if one of the following conditions is met: the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead; the controller no longer needs the personal data, but you require it for the assertion, exercise or defence of legal claims; you have objected to processing pursuant to Article 21 (1) pending verification of whether the legitimate grounds of the controller override yours.

Where processing has been restricted, such personal data may — with the exception of storage — only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Right to data portability

You have the right to receive the personal data that you have provided to a controller in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent or on a contract and the processing is carried out by automated means.

When exercising the right to data portability, you have the right to have the personal data transmitted directly from one controller to another controller, insofar as this is technically feasible.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data carried out on the basis of Art 6 (1) lit e or f GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.

Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

Right to withdraw consent

You have the right to withdraw consent given pursuant to Art 6 (1) lit a or Art 9 (2) lit a at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna, T.: 00431521522569, E.: dsb@gsb.gv.at, if you are of the opinion that the processing violates applicable data protection law.

Other Information

The provision of personal data is partly required by law or necessary for the conclusion of a contract. You are generally not obliged to provide the data. If you do not provide the data, no contract can be concluded.

There is no automated decision-making, including profiling, pursuant to Article 22 (1) and (4).

Last updated: June 2025