Privacy Policy

1. Introduction

torona GmbH (registration number FN492781s) is committed to protecting and respecting your privacy. This privacy policy explains how we collect, use, and protect your personal data when you visit our website or use our liquidity management services. We are the data controller for the purposes of the General Data Protection Regulation (GDPR) and Austrian data protection laws.

2. Data We Collect

The data we collect from you may include the following categories of personal information:

• Contact information: name, email address, telephone number, postal address
• Professional information: organisation name, job title, business sector
• Communication data: enquiries, correspondence, and feedback you provide
• Technical data: IP address, browser type, device information, website usage data
• Marketing data: your preferences for receiving marketing communications
• Financial information: relevant to our liquidity management services (where applicable)

3. How We Use Your Information

We use the personal data we collect for the following purposes and on the following legal bases:

• Service provision: To provide our liquidity management services and respond to your enquiries (legal basis: contract performance and legitimate interests)
• Communication: To communicate with you about our services and respond to your requests (legal basis: contract performance and legitimate interests)
• Business operations: To manage our business relationship and improve our services (legal basis: legitimate interests)
• Legal compliance: To comply with our legal obligations under Austrian and EU law (legal basis: legal obligation)
• Marketing: To send you information about our services where you have consented or where we have legitimate interests

4. Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

5. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

• Professional advisers including lawyers, accountants, and auditors
• IT service providers and data processors who assist with our operations
• Regulatory authorities where required by law
• Third parties in connection with business transfers or restructuring

We do not sell your personal data to third parties. Any sharing is conducted in accordance with applicable data protection laws and appropriate safeguards.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and reporting requirements. Generally, we retain client data for seven years after the end of our business relationship, in accordance with Austrian commercial law requirements. Marketing data is retained until you withdraw consent or for a maximum of three years from your last interaction with us.

7. International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). Where we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions by the European Commission.

8. Your Rights

Under the GDPR and Austrian data protection law, you have the following rights regarding your personal data:

• Right of access: You can request copies of your personal data
• Right to rectification: You can request correction of inaccurate data
• Right to erasure: You can request deletion of your data in certain circumstances
• Right to restrict processing: You can request limitation of processing in certain circumstances
• Right to data portability: You can request transfer of your data to another organisation
• Right to object: You can object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection principles.

10. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us immediately.

11. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date above.

12. Contact Us

If you have any questions about this privacy policy, wish to exercise your rights, or have concerns about how we handle your personal data, please contact us using the following contact information:

13. Supervisory Authority

You have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde) if you believe we have not handled your personal data in accordance with applicable data protection laws. You can contact them at www.dsb.gv.at.