Privacy Policy

Last Updated: July 3, 2025

1. Data Controller Information

Data Controller: KWILA Technology KG

Address: 1190 Vienna, Kahlenberger Str. 82/5, Austria

Contact Information:

Email: contact@kwila.tech

Website: www.kwila.tech

2. Legal Framework

This Privacy Policy is governed by:

– EU General Data Protection Regulation (GDPR) 2016/679

– Austrian Data Protection Act (DSG)

– Austrian E-Commerce Act (ECG)

– Austrian Telecommunications Act (TKG)

3. Data Protection Officer

As we are a small business, we are not required to appoint a Data Protection Officer. However, for any questions regarding data protection or the exercise of your rights, you can contact us at contact@kwila.tech.

4. What Personal Data We Collect

Newsletter Subscription Data

  • Email address (required for newsletter delivery)
  • Name (optional, if provided during subscription)
  • Subscription date and source (where you signed up)

Technical Data

  • Email engagement data: Open rates, click-through rates, time of opens
  • Device and browser information: Used for email optimization
  • IP address: Recorded during subscription for security purposes and to demonstrate compliance with anti-spam laws

Interactive Content Data (if applicable)

  • Survey responses: Your answers to subscriber surveys and polls (optional)
  • Content ratings: Scores and feedback you provide on newsletter content (optional)
  • Topic suggestions: Ideas and article suggestions you submit (optional)
  • Feedback and comments: Any feedback you provide about our newsletter (optional)

5. Legal Basis for Processing

We process your personal data based on the following legal bases:

  • Consent (GDPR Article 6(1)(a)): Your explicit consent when subscribing to our newsletter and participating in surveys or providing feedback.
  • Legitimate Interest (GDPR Article 6(1)(f)): For improving our newsletter content, measuring engagement, and analyzing subscriber feedback to enhance our service.
  • Legal Obligation (GDPR Article 6(1)(c)): When required by law, such as maintaining records for anti-spam compliance under the Austrian E-Commerce Act (ECG) and the Austrian Telecommunications Act (TKG).

6. How We Use Your Data

Primary Uses

  • Newsletter delivery: Sending you our newsletter content based on your subscription preferences.
  • Content personalization: Tailoring content based on your preferences and feedback.
  • Performance analysis: Understanding engagement to improve our newsletter.
  • Subscription management: Managing your preferences and subscription status.

Communication Purposes

  • Send you the newsletter content you subscribed to.
  • Notify you of important changes to our newsletter or this policy.
  • Respond to your inquiries, feedback, or topic suggestions.

What We Do NOT Do

  • Sell or rent your email address to third parties.
  • Use your data for unrelated marketing purposes.
  • Share your information with partners for their marketing.
  • Send promotional content beyond what you subscribed to.

7. Data Retention Periods

  • Active subscribers: Data retained while you remain subscribed.
  • After unsubscribing: Email address kept for 30 days to honor unsubscribe requests, then deleted.
  • IP addresses: Retained for 6 months for security and anti-spam compliance
  • Survey responses: Individual responses kept for 2 years, anonymized data may be retained longer.
  • Content ratings and suggestions: Kept for 2 years to inform content strategy.
  • Engagement data: Anonymized engagement statistics may be retained for up to 2 years.
  • Legal compliance: Some data may be retained longer if required by Austrian or EU law.

8. Third-Party Services

Email Service Provider

We use MailerLite [https://www.mailerlite.com/], an email service provider based in the European Union, to deliver our newsletter. MailerLite processes your data on our behalf and is bound by strict data protection agreements in accordance with GDPR Article 28. MailerLite’s privacy policy can be found here.

Analytics Tools

We use analytics tools provided by MailerLite to understand newsletter performance and subscriber engagement:

  • Email analytics: Open rates, click tracking, delivery statistics.
  • Survey analytics: Analysis of survey responses and feedback patterns (if applicable).
  • Content performance: Tracking which content receives the highest ratings (if applicable).

All third-party services are GDPR-compliant and process data only as instructed by us.

9. Data Sharing and Transfers

Limited Sharing

We only share your data with:

  • MailerLite: Our email service provider, for newsletter delivery and analytics.
  • Legal authorities: When required by Austrian or EU law.

International Transfers

As MailerLite is based in the European Union, your data is primarily processed within the EEA. In the unlikely event that data is transferred outside the EEA, we ensure adequate protection through:

  • Adequate protection through EU adequacy decisions.
  • Standard contractual clauses with service providers.
  • Other legally recognized safeguards in accordance with GDPR Chapter V.

10. Your Rights Under GDPR

Access and Control

  • Right of access (GDPR Article 15): Request a copy of your personal data.
  • Right to rectification (GDPR Article 16): Correct inaccurate information.
  • Right to erasure (GDPR Article 17): Request deletion of your data.
  • Right to data portability (GDPR Article 20): Receive your data in a portable format.

Subscription Management

  • Right to withdraw consent (GDPR Article 7): Unsubscribe at any time.
  • Right to restrict processing (GDPR Article 18): Limit how we use your data.
  • Right to object (GDPR Article 21): Object to processing based on legitimate interests.

How to Exercise Your Rights

  • Unsubscribe: Click the unsubscribe link in any newsletter.
  • Update preferences: Use the preference center link in newsletters.
  • Withdraw survey consent: Contact us to opt out of future surveys.
  • Delete specific data: Request removal of survey responses or suggestions.
  • Data requests: Email us at contact@kwila.tech
  • Account access: https://subscribepage.io/Xy6G3w#CTA-subscribe-1

We respond to requests within 30 days in accordance with GDPR Article 12.

11. Consent and Subscription Process

How You Subscribe and Participate

  • Double opt-in: We use confirmed opt-in to ensure valid consent in accordance with GDPR Article 7 and the Austrian E-Commerce Act (ECG).
  • Clear information: You’re informed about what you’re subscribing to.
  • Easy unsubscribe: Every newsletter includes an unsubscribe link.
  • Voluntary participation: Surveys, ratings, and suggestions are always optional.
  • Separate consent: Interactive features may require additional consent.

Withdrawal of Consent

  • You can withdraw consent at any time by clicking the unsubscribe link in any newsletter or by contacting us at contact@kwila.tech
  • Unsubscribing is free and immediate.
  • We’ll confirm your unsubscription and delete your data within 30 days.

12. Data Security

We implement appropriate technical and organizational security measures to protect your data in accordance with GDPR Article 32, including:

  • Encryption: Data encrypted in transit (TLS) and at rest (AES-256).
  • Access controls: Limited access to authorized personnel only, based on the principle of least privilege.
  • Regular security reviews: Ongoing security assessments and penetration testing.
  • Secure service providers: All partners, including MailerLite, meet high security standards and are GDPR-compliant.
  • Data breach procedures: In case of a data breach, we will notify you and the Austrian Data Protection Authority within 72 hours, as required by GDPR Article 33.

13. Children’s Privacy

Our newsletter is not intended for children under 16, in accordance with GDPR Article 8 and Austrian data protection laws. We do not knowingly collect personal information from children under 16. If we become aware of such data collection, we will immediately delete the information.

14. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal effects or significantly affects you in accordance with GDPR Article 22. Any automation is limited to:

  • Email delivery optimization: Technical improvements to delivery based on engagement data.
  • Content suggestions: Based on general preferences and ratings you’ve provided.
  • Survey targeting: Selecting relevant surveys based on your interests (with your consent).

15. Your Right to Complain

If you’re not satisfied with how we handle your personal data, you can:

  • Contact us directly at contact@kwila.tech
  • Lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde):
    • Website: https://www.dsb.gv.at/
    • Address: Barichgasse 40-42, 1030 Wien, Austria
    • Email: dsb@dsb.gv.at
    • Phone: +43 1 52 152-0

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we do:

  • We’ll update the “Last Updated” date at the top of this policy.
  • Significant changes will be communicated via newsletter.
  • You’ll have the option to read the changes.
  • Continued subscription after notification indicates acceptance.

17. Contact Information

For privacy questions or exercising your rights:

Email: contact@kwila.tech

Subject: “Privacy Request – [Type of Request]”

For general newsletter inquiries:

Email: contact@kwila.tech

Postal Address: KWILA Technology KG, 1190 Vienna, Kahlenberger Str. 82/5, Austria

This Privacy Policy was last modified on July 3, 2025.

Quick Reference: Your Rights

  • Unsubscribe anytime: Click the link in any newsletter.
  • Update preferences: Use our preference center.
  • Skip surveys: Participation is always voluntary.
  • Request your data: Email us for a copy of your information.
  • Delete your data: Request complete removal of all data.
  • Delete specific responses: Remove survey answers or suggestions.
  • File a complaint: Contact the Austrian Data Protection Authority.
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