Privacy Policy

for the use of the online platform and services of TwinVision e.U.
FN 465994k, Handelsgericht Wien
Engerthstraße 90/66
1200 Vienna, Austria
contact@twinvision.at

Last updated: 04/18/2018

1. GENERAL

1.1. RaceDirector Product

The RaceDirector app is a product of TwinVision e.U. The concept of the RaceDirector app and the RaceDirector.at platform (both „RaceDirector Product“) is based in part on the publication of details regarding individual users by making such details accessible to other users via the RaceDirector Product and social networks, e.g. Facebook.

1.2. Compliance with Data Protection Laws

The collection, administration and use of personal details by TwinVision e.U. complies with applicable data protection laws by ensuring that, amongst others and subject to 3.1, each user is able to decide herself, which personal details shall be made accessible to other users.

2. PERSONALLY IDENTIFIABLE INFORMATION COLLECTED BY TWINVISION e.U.

2.1. Personally Identifiable Information

TwinVision e.U. collects information from users upon registration on its website (the “Registration” and a user then a “Registered User”) and in connection with the use of any of the RaceDirector Product. Personally identifiable information (personenbezogene Daten) within the meaning of § 4.1 of the Austrian Data Protection Act (DSG 2000) shall be saved and used in particular in order to offer new applications to the user, to improve such applications and conform them to the users’ needs.

2.2. Data Collection

certain user data is collected in several ways (the “Registration Information”)

2.2.1. Mandatory Information

Certain information has to be given by a user in order to register for the RaceDirector Product, such as:

• Email address;
• User name
• country

2.2.2. Optional Information

Certain user information is optional on the RaceDirector website and can also be added or deleted later on by the user, such as:

• Personal Information:
• Profile picture
• Comments to the profil picture

2.3. Additional User Data

After Registration different types of data are collected by TwinVision e.U. (the “Additional User Data” and, together with the Registration Information, the “User Information”), such as:

• Racetrack
• Type of car
• Date of ride
• Track Day Type (optional)
• Weather conditions (optional)
• Car brand (optional)
• Data logger (optional)

3. PRIVACY SETTINGS AND LIVE TRACKING

3.1. Privacy Settings

Every user can change the privacy settings applicable to his or her account for the RaceDirector Product.

3.1.1. General

In this way, the user can decide for different categories (e.g. profile data, uploaded position data etc), subject to 2.2.2 and 2.3, who can see the User Data and position data collected: public, anonymised or privat. The default privacy settings are set to “public” for all users.

3.2. Position Data

The RaceDirector Product include position data of the recorded rides, which enable another user to see those data within the RaceDirector Product. The user may anonymise these data or forbid access to that data for any otehr user.

4. USE AND SHARING OF PERSONALLY IDENTIFIABLE AND NON-PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES

4.1. Confidentiality and Security

TwinVision e.U. deems all user information confidential and does not disclose such information without the express informed consent of the user. TwinVision e.U. has implemented reasonable security policies and procedures designed to protect user information.

4.2. Registration

With Registration, the user explicitly agrees that TwinVision e.U. shall have the right to use all collected personally identifiable information, for purposes of the RaceDirector Product and generally agrees with this Privacy Policy.

4.3. Sharing of Information

TwinVision e.U. does not pass on personally identifiable information (see Section 2, above) to third parties, except as response to lawful requests from federal, state, local, or foreign law and civil enforcement agencies, as required by law, or with the explicit consent of the user, especially as set forth herein. TwinVision e.U. implements all reasonable measures to prevent the unauthorized access by third parties to saved details.

4.4. Advertising

The user explicitly consents to the storage and use of non-personally identifiable information for purposes of newsletter marketing or on www.racedirector.at by TwinVision e.U. or its partners. Registered Users may also opt out of advertising through a mechanism on the www.racedirector.at website.

5. PLUGINS AND WIDGETS FOR SOCIAL MEDIA

5.1. The RaceDirector Product include social media plugins, such as (i) Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA; (ii) Google +, 1600 Amphitheatre Parkway, Mountain View, CA 94043; (iii) Twitter, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; (iv) WhatsApp, WhatsApp Inc., 650 Castro Street, Suite 120-219, Mountain View, CA 94041, USA.

5.2. Such plugins can recognize a user’s IP address and the page visited on the Racedirector.at platform and, possibly, store cookies, so that the services offered by TwinVision e.U. work properly. Social media plugins and widgets are hosted either by third party providers or directly by us. Your interactions with these plugins are subject to this privacy policy or the privacy policy of any third party that offers such feature. TwinVision e.U. is not responsible for the use of, or guidelines regarding the use of, personal data by third party providers.

5.3 Users may recognize the respective plugins, e.g., by the respective logo or other respective characteristic typical for the respective social media-platform on our pages.
You can find an overview of Facebook-plugins here: http://developers.facebook.com/docs/plugins/. You can find an overview of Google+-plugins here: https://developers.google.com/+/web/. You can find an overview of Twitter-plugins here: https://dev.twitter.com/web/overview.

5.4. If a user interacts with the plugins, e. g. by clicking on the Facebook “Like-Button” or entering a comment, while being logged in to such user’s Social Media-account on Facebook, Google+, or Twitter, a user links the contents of the RaceDirector pages to his or her respective social media-profile. Thereby, Facebook/Google+/Twitter can associate a user’s visit of the RaceDirector page or use of RaceDirector Products with such user’s social media-account. TwinVision e.U. as the provider of the RaceDirector Product does not have any knowledge of the content of the transmitted data or its usage by Facebook, Google+, or Twitter. Users can also share finished activites via Whatsapp. Users can find more information on the issue of data transmission in the privacy policy of the respective social media-platform:

• Facebook: http://www.facebook.com/about/privacy/
• Google+: http://www.google.com/intl/en/policies/privacy/
• Twitter: https://twitter.com/privacy
• Whatsapp: https://www.whatsapp.com/legal/?I=en#privacy-policy

5.5. If users do not want to have the respective social media-platform associate their visits on our site with their social media-account, users must log out from their social media-account.

6. COOKIES

6.1. General

Several areas of the RaceDirector website use ‘cookies’ ─ small text files that are placed on the user’s computer and stored by the browser. They are used by TwinVision e.U. to provide a more user-friendly, effective and secure service. Cookies also enable TwinVision e.U. to identify a user’s browser and offer services to such user. Cookies do not contain any personally identifiable information.

6.2. Installation

You can prevent the installation of cookies by entering the corresponding settings in your browser software. However, please note that in this case you may not be able to use the complete range of functions of the RaceDirector.at platform to its full extent.

7. GOOGLE ANALYTICS AND APP ANALYTICS

7.1. The RaceDirector Product use Google Analytics, a web analysis service by Google Inc. (“Google”). Google Analytics uses ‘cookies’ (see Section 6, above). The information about your visit collected by the cookies, including your IP address, is usually transferred to a Google server in the USA and saved there. To the extent that the RaceDirector Products have activated IP anonymization, Google first abbreviates your IP address within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases, will the full IP address be transferred to a Google server in the USA or Asia and abbreviated there. Google will use the information collected on behalf of the website operator to evaluate your use of the RaceDirector Product, to compile reports about your activities within the RaceDirector Product, and to provide further services to TwinVision e.U. related to use of the RaceDirector Product and Internet use. Google will under no circumstances associate the IP address transmitted by your browser within the operations of Google Analytics with other Google data.

7.2. You can prevent the data related to your use of the RaceDirector platform, including your IP address, generated by the cookies from being recorded by Google and Google’s processing of this data by downloading and installing the browser plugin from the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

7.3 Furthermore, you can prevent the future data capture by setting an Opt Out-Cookie via the following link: Deactivate Google Analytics Further information regarding terms of use and privacy provisions may be found on the websites http://www.google.com/analytics/terms/us.html and https://www.google.de/intl/en/policies/. The RaceDirector Product expanded the Google Analytics-Service with the “anonymizeIP”-Code to anonymize the user’s IP-address.

7.4 The RaceDirector Products use Google DoubleClick for Publishers (“DFP”). DFP uses Cookies to provide the user with user-relevant advertisements – further information may be found at https://support.google.com/dfp_premium/answer/2839090?hl=en. The user may disable the DFP’s cookie placement and the placement of user-relevant advertisements for use of the RaceDirector platform via the website: http://www.google.com/ads/preferences.

7.5. For the mobile apps on iOS and Android the services of adjust.io (by adjust GmbH, Saarbrücker Str. 38a, 10405 Berlin) are used.

8. CHANGES TO PRIVACY POLICY

8.1. Changes to this Privacy Policy require the consent of the respective user, to whom the changed Privacy Policy shall apply. If TwinVision e.U intends to implement such changes, it will give the user as much prior notice of such changes as possible. Such notice shall be made on the relevant pages of the RaceDirector platform or on any other device through which the user accesses the RaceDirector Product. Any such modifications will take effect within thirty days of publication.

9. DELETION OF USER INFORMATION

9.1. In case of a termination of the Registered User’s account,

9.1.1 all personal details provided by the user upon Registration shall be deactivated. Any details made public by the user, e.g., routes, notes on other Registered Users’ walls, will be (i) anonymized, i.e., it will be made clear that such details were provided by a deleted user, or (ii) deleted, in the event of cancellation, within thirty days; and

9.1.2 upon the Registered User’s request, all User Information not required for TwinVision e.U.’s performance of contractual obligations or compliance with statutory retention obligations, shall be irrevocably deleted. The user shall request such deletion by email sent to contact@racedirector.at, which shall include the email address provided to TwinVision e.U. upon Registration, or via the website. TwinVision e.U. will comply with such requests within ten days and maintain a record of the deletion for one year after the deletion.

10. YOUR CONSENT

10.1. By using our site as a non-registered user, you consent to our privacy policy only for those areas not subject to Registration. Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website and apps. https://www.racedirector.at/en/terms-and-conditions

11. PARTNER PROGRAM

11.1 Amazon Partner Program

We participate in the Amazon EU Partner Program. On our site blog.racedirector.at Amazon ads and links to the website of Amazon.de are included, where we can earn money on advertising reimbursement. Amazon uses cookies to track the origin of the orders. This will enable Amazon to recognize that you have clicked the affiliate link on our website.

The storage of “Amazon cookies” is based on Art. 6 lit. f DSGVO. The website operator has a justified interest in this, since only through the cookies, the amount of its affiliate remuneration can be determined.

For more information about Amazon’s data usage, please refer to the Amazon Privacy Policy: https://www.amazon.com/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401.

11.2 Other Affiliate Programs

Furthermore, we use z. B. Affiliate program of the following providers:

• viglinks

Affiliate links are marked with an asterisk (*) so you can see them at first glance.