Third Party Index

Snapshot 44739

Document
Privacy policy
URL
https://cdn.prighter.com/legal/Prighter-PrivacyPolicy.pdf
Fetched
HTTP status
200
Content type
application/pdf
Fetch mode
pdf
Size
264919 bytes
SHA-256 (raw)
66045617720c1213875f4a4f910da47f845713dc70e0ce1720cb45c72e229c82
SHA-256 (normalized text)
9d991ca9a6afae65bdefd733576c9d025191c655d6500fae601850db7b3d2082

Normalized text

Scripts and page chrome removed; this is what change detection compares.

PRIVACY POLICY
Prighter GmbH and our affiliates (“we”, “us”, “our” or “Prighter”) value your privacy and are
committed to safeguarding your Personal Data, which is a responsibility that we take very seriously.

This Privacy Policy explains how we may use the Personal Data we collect when you visit our website
https://prighter.com/ (“Website”), inquire about our products, purchase or subscribe to a product
through our Website, apply for a role within our organisation, or subscribe to our marketing
communications. It also explains how we comply with the EU legislation related to data protection (EU
General Data Protection Regulation (“GDPR”)) and what your rights are under this legal framework.

Controller:                    Prighter GmbH (“Prighter“)
                               Schellinggasse 3/10
                               1010 Vienna
                               Austria
Data Protection Officer:       DPO of Prighter GmbH
                               Email: dpo@prighter.com

1. DEFINITIONS

Unless otherwise indicated, capitalized terms used in this Privacy Policy are defined in Annex 1. Most
of the definitions are derived from the EU General Data Protection Regulation.

2.    WHAT TYPE OF PERSONAL DATA DO WE COLLECT FROM YOU?

Personal Data means any information relating to you which allows us to identify you, either directly
from that data or because we combine that information with other data about you.

When you use our Website, including to create an account with us and purchase products from our
Website, subscribe to our marketing communications, or when we interact with you in relation to our
products, you may provide us with your Personal Data, or we may obtain Personal Data about you.

We may process the following Personal Data:

▪     Contact details and personal identifiers: such as your name, email address, billing address;

▪     Purchase data: data on the products you have asked us to provide to you, such as date and time
      of purchase, customer number, order number, invoice number;

▪     Payment data: information relating to your payment and receipt details, tax identification
      number, refund and details of payment transactions with you;

▪     Records of your interactions with us: such as any feedback, enquiries or complaints you make,
      questions you have, or content of any other interactions with us;

▪     Internet information: including your use of and movements through our Website, the date and
      time of your visit or use of our Website, IP addresses, IP location, device information such as
        type of browser, type of device, screen size, internet service provider and operating system and
        other IT system identifying information;

▪       Job information: such as your role and function in the company, employment and business
        activity;

▪       Application information: information obtained from your CV, photograph, content of your
        application;

Your marketing preferences: so that we know whether and how we should contact you. You can stop
receiving our marketing communications at any time, free of charge, through the methods displayed
as part of any communication such as the unsubscribe link in our emails. Or further information on
this please see the section below on Direct Marketing.

3.      WHERE DO WE COLLECT YOUR PERSONAL DATA FROM?

We may collect Personal Data from several sources. These include the following:

▪       Directly from you: when you use our Website, order our products, provide your feedback or
        make a complaint, contact us by email, or communicate with us directly in some other way.

▪       Our website: provides us with information about how you use it and the devices that you use
        to connect to our Website. Like many other Websites, we use so-called “cookies”. Cookies are
        small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit
        our Website. If you have given your consent to our use of cookies, we do so to improve the use
        of our Website or to analyze our Website. You can revoke your consent to our use of cookies
        any time. Please find a detailed list of all cookies we use in our Cookie Policy
        https://cdn.prighter.com/legal/Prighter-CookiePolicy.pdf.

If you are providing information regarding other individuals to us, it is your responsibility to ensure
that you have the right to provide the information to us.

]
4.      WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT LEGAL
        BASIS?

The table below describes the main purposes for which we process your personal data, the categories
of your information involved, and our lawful basis for doing so.

    Purpose                      Personal Data used              Lawful basis
    So that we can provide our   IP address, browser type,       We have a legitimate interest in our
    website to you               device ID, IP location          website working properly.
    To improve our website       IP address, website activity,   We have a legitimate interest in ensuring
    security, offer IT support   date and time of your visit     our systems are secure.
    and troubleshooting          or use of our website,
                                 device information
 To manage your purchases      Name, email         address,   This is necessary to fulfil our contract
 and provide products to       billing address                with you.
 you

 To create an account with  Name, email address,              This is necessary to fulfil our contract
 us                         telephone          number,        with you.
                            address, payment data,
                            purchase     history  and
                            customer number
 To invoice you and receive Name, email address,              This is necessary to fulfil our contract
 payments from you          billing address, customer         with you.
                            number, invoice number,
                            tax identification number,
                            and other payment data
 Marketing products which Name, email address and             We have a legitimate interest to provide
 may be of potential        marketing preferences             you with information about or products
 interest to you and                                          including those that are the same or
 offering promotions                                          those similar to the ones you have
                                                              inquired about.

                                                              If we cannot rely on legitimate interest
                                                              as our lawful basis for processing, then
                                                              we will obtain consent from you.

 Provide you with our          Name, email address,           We only send you newsletters if you
 newsletter                    marketing preferences          gave us your consent.

 To deal with inquiries, and   Name, email address and        This is necessary to fulfil our contract
 other communications          customer number                with you.
 from you
 To manage and select          Name, email address and        This is necessary to fulfil our contract
 candidates who applied        other information              with you.
 for a position with us        provided in your CV and
                               application
 For the purpose of            Contact details, invoice       We have a legal obligation to comply
 complying with any legal      number and tax                 with   any    legal  or    regulatory
 and regulatory                identification number          requirements.
 requirements
 Storage of records relating   All the personal               To be able to manage and fulfil our
 to you and also records       information we collect         contract with you, we may have a legal
 relating to our business      about you                      and/or regulatory obligation to do so,
                                                              and we also have a legitimate interest to
                                                              keep proper records.

Some of your Personal Data may be required due to legal, contractual, or other obligations. Failure to
provide this data may impact our ability to fulfil our contract with you or comply with relevant legal
obligations. For other Personal Data, whilst you may not be under an obligation to provide it to us, if
you do not provide it, we may not be able to properly perform our services for you. Without your
Personal Data, you may be unable to complete purchases or register an account on our Website.
Providing Personal Data for marketing and newsletters is optional. Refusal to provide this data has no
negative consequences but means that we cannot offer personalised marketing messages or
promotional offers. If you provide us your consent for marketing purposes, you can revoke your
consent or object the processing at any time by utilizing the following website: [link to Prighter page]
or by following the information in section “Contact Information”.

5.    WHO WE SHARE YOUR PERSONAL DATA WITH?

In order to operate our Website and provide you with the products you have purchased we may need
to share your Personal Data with third parties. This includes sharing your Personal Data with
companies engaged by us to manage our relationship with you and provide you the services described
above.

We may share your personal data with the following recipients:

▪     Sub-contractors: such as our marketing and service technology providers, direct marketing
      brokers, cloud service providers, payment service providers and other sub-contractors. For a
      detailed list of engaged sub-contractors please see Annex II.

▪     Consultants and accountants: such as legal or tax consultants and accountants.

▪     Government and law enforcement agencies: where we are required to do so by law or to assist
      with their investigations or initiatives.

We do not disclose Personal Data to anyone else except as set out above unless we have your consent,
or we are legally obliged to do so. These recipients will only process your Personal Data to perform
tasks and duties on our behalf and in compliance with this Privacy Policy and governing data protection
laws.

6.    DIRECT MARKETING

From time to time, we may contact you by email with information about products we believe you may
be interested in.

Marketing emails and newsletters will only be sent to you based on the preferences you set when you
create your account, tell us that you wish to receive marketing related messages or when you have
purchased similar products from us previously.

You can opt out any time if you do not wish to receive any marketing messages by clicking on the
unsubscribe link in any marketing email you receive to unsubscribe from future marketing
communications.

7.    INTERNATIONAL DATA TRANSFERS

In the course of our operations, it may be necessary to transfer your Personal Data to recipients
located outside the European Union (EU), European Economic Area (EEA), or the United Kingdom (UK).
These transfers may be to our Clients, partners, or service providers who are located in regions with
differing data protection laws than those in your country. When transferring your Personal Data
internationally we implement appropriate safeguards to ensure the security and confidentiality of
your data. These safeguards may include for example Standard Contractual Clauses (SCCs) approved
by the European Commission or applicable supervisory authority.

8.    HOW LONG DO WE KEEP PERSONAL DATA FOR?

Generally, we will retain your Personal Data for as long as we need it for the purposes for which it was
collected. The duration for which we retain your Personal Data will differ depending on the type of
information and the reason why we collected it from you. However, in some cases Personal Data may
be retained on a long-term basis: for example, Personal Data that we need to retain for legal purposes
will normally be retained in accordance with usual commercial practice and regulatory requirements.

In addition, we may be allowed to retain Personal Data whenever you have given consent to such
processing (e.g. subscription to our newsletter), as long as such consent is not withdrawn.

9.    DATA SECURITY

We take the security of your information very seriously and only handle Personal Data as permitted
by data protection regulations. We use a variety of technical and organizational measures to help
protect your Personal Data from unauthorized access, disclosure, modification, loss or destruction in
accordance with applicable data protection laws. When handling Personal Data, our employees are
obliged to comply with the regulations of the GDPR.

10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have the following rights in relation to your Personal Data:

Right of Access - you have the right to be informed about how we are using your Personal Data and
the right to access that data that we hold about you.

Right to Erasure or "Right to be Forgotten" – You have the right to ask us to delete your Personal Data
provided that there are no valid grounds for us to keep it, for example we may have to keep some or
all of the Personal Data to comply with legal obligation or in respect of any legal claims.

Right to Data Portability – You have the right to receive the Personal Data you have provided to us in
a digital format or in certain circumstances and where technically feasible the right to ask us to
transmit the data to another organization.

Right of Rectification – You have the right to ask us to amend the Personal Data that we hold about
you where you believe it is inaccurate or incomplete.

Right to Object - In certain circumstances, you have the right to object to the processing of your
Personal Data and to ask us to block, erase and restrict our use of your personal data.

Automated Decision Making – We may process your Personal Data by solely automated means
(without human intervention), including for profiling. Where such processing may have a legal or
similarly significant effect on you, you have the right not to remain subject to any decisions based on
such automatic processing, except as otherwise provided by law. You have the right to understand
when and how automated decisions are made about you, and the factors involved and you have the
right to challenge these decisions, request human intervention, express your point of view, and seek
a review of the decision.

Right to Withdraw Consent or Right of Opposition – If you have provided your consent to the
collection, processing and transfer of your personal data, you have the right to fully or partly withdraw
your consent. Once we have received notification that you have withdrawn your consent, we will no
longer process your information for the purpose(s) to which you originally consented unless there is
another legal ground for the processing.

Right of Limitation - You have the right to request the limitation of the Processing of your Personal
Data, in the form of: (i) suspension of Processing or (ii) limitation of the scope of Processing to certain
categories of Personal Data or purposes of Processing.

Right to complain – You have the right to complain to the supervisory authority, in addition to us.

The period for handling a request is 30 days unless it is a particularly complex request.

Once our specified retention period expires, we shall delete the relevant Personal Data. Therefore,
the right to access, the right to erasure, the right to rectification and the right to data portability
cannot be enforced after the expiration of such retention period.

11. PROCESSING DATA IN RELATION TO CHILDREN

Our products and services are not intended for and shall not be used by individuals under the age of
18. Prighter does not knowingly collect Personal Data from persons under 18 or allow them to register.
If it comes to our attention that we have collected or processed Personal Data from such a person, we
may delete this information without notice. If you have reason to believe that this has occurred, please
contact us using the following email: support@prighter.com

12. CHANGES TO OUR DATA PROTECTION PROVISIONS

We may need to make changes to this Privacy Policy to ensure that it complies with current legal
requirements or to implement changes to the services detailed in the Privacy Policy, e.g., when
introducing new services and products. In this case, your future visits to our Website will be subject
to the updated Privacy Policy.

13. CONTACT INFORMATION
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use
your Personal Data, or your choices and rights regarding such use please do not hesitate to contact us
by:

Email at: support@prighter.com
Post to: Schellinggasse 3/10, 1010 Vienna, Austria

This Policy was last updated: August 2025
                                                                                             Annex 1.

ADM              means Automated decision-making;
Consent of the   means any freely given, specific, informed and unambiguous indication of the Data
Data Subject     Subject's wishes by which he or she, by a statement or by a clear affirmative action,
                 signifies agreement to the Processing of Personal Data relating to him or her;
Contract         means concluding, maintaining, and completing of a contract concluded between the
Performance      Controller and a Data Subject, including Processing activities which take place at the
                 request of the Data Subject before entering into a contractual relation;
Controller       means 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; where the purposes and means of such Processing are determined by Union or
                 Member State law, the Controller or the specific criteria for its nomination may be
                 provided for by Union or Member State law;
Data Subject     is any natural person whose Personal Data is being collected, held or processed.
                 Examples of a Data Subject can be an individual, a customer, a prospect, an employee,
                 a contact person, etc;
Direct           means personal data processed to communicate a marketing or advertising message.
Marketing        This definition includes messages from commercial organisations, as well as from
                 charities and political organisations;
General Data     is a regulation in EU law on data protection and privacy in the European Union (EU) and
Protection       the European Economic Area (EEA); Regulation (EU) 2016/679 of the European
Regulation       Parliament and of the Council of 27 April 2016 on the protection of natural persons with
(GDPR)           regard to the processing of personal data and on the free movement of such data, and
                 repealing Directive 95/46/EC (General Data Protection Regulation) https://eur-
                 lex.europa.eu/eli/reg/2016/679/oj ;
Legitimate       means the Controller’s interest to process Personal Data in order to carry out tasks
Interest         related to the Controller‘s business activities. The processing of Personal Data in that
                 context may not necessarily be justified by a legal obligation or carried out to execute
                 the terms of a contract with a Data Subject;
Personal Data    means any information relating to an identified or identifiable natural person ('Data
                 Subject'); an identifiable natural person is one who can be identified, directly or
                 indirectly, in particular by reference to an identifier such as a name, an identification
                 number, location data, an online identifier or to one or more factors specific to the
                 physical, physiological, genetic, mental, economic, cultural or social identity of that
                 natural person.
Processing       means any operation or set of operations which is performed on Personal Data or on
                 sets of 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;
Processor        means a natural or legal person, public authority, agency or other body which processes
                 Personal Data on behalf of the Controller;
Recipient        means a natural or legal person, public authority, agency or another body, to which the
                 Personal Data are disclosed, whether a third party or not. However, public authorities
                 which may receive personal data in the framework of a particular inquiry in accordance
                 with Union or Member State law shall not be regarded as Recipients; the Processing of
                 those Personal Data by those public authorities shall be in compliance with the
                 applicable data protection rules according to the purposes of the Processing;
                                                                                    Annex 2.
List of Sub-Processors

Our processors reported the following sub-processors:

       Sub-Processor                Registered Office (Country)   Basis for transfer to third party
                                                                  country
 1     DigitalOcean LLC             USA                           EU-U.S.       Data        Privacy
                                                                  Framework
 2     Microsoft (Ads, Entra, USA                                 EU-U.S.       Data        Privacy
       Office 365)                                                Framework
 3     Google LLC/ Google Ads USA                                 EU-U.S.       Data        Privacy
                                                                  Framework
 4     Hetzner Online               Data center within EEA        n/a
 5     The Rocket Science Group, USA                              EU-U.S.       Data       Privacy
       LLC d/b/a Mailchimp                                        Framework
 6     Salesforce, Inc.          USA                              EU-U.S.       Data       Privacy
                                                                  Framework
 7     Sentry                       USA                           EU-U.S.       Data       Privacy
                                                                  Framework
 8     Strato                       Germany                       n/a
 9     Stripe Inc                   USA                           EU-U.S.       Data       Privacy
                                                                  Framework
 10    Storyblok                    Austria                       n/a
 11    Twillio Inc                  USA                           EU-U.S.       Data       Privacy
                                                                  Framework
 12    Typeform                     Spain                         n/a
 13    ZenLeads Inc (Apollo.io)     USA                           EU-U.S.       Data       Privacy
                                                                  Framework
 14    Zoom                         USA                           EU-U.S.       Data       Privacy
                                                                  Framework