Data privacy and data security are important to the Upway Association (“Upway”; “we”). We process your personal data responsibly, in accordance with applicable legal provisions and in accordance with this privacy policy.

f Statement on Data Privacy Audit

Contents of this Privacy Policy

In this Privacy Policy, we inform you about how we collect and process personal data when you visit our website at www.upwayapp.com (“Website”) or https://app.upwayapp.com (“WebApp”), contact us, or use our services.

Controller for data processing

Upway is responsible for the data processing described in this privacy policy.

If you have any questions or if you wish to exercise your data protection rights, please contact us at info@upwayapp.com or write to us at:

Verein Upway
Werner Klecka
Seestrasse 6
2576 Lüscherz

Our representative in the EU is Prometa GmbH, located at Bahngasse 6, 2700 Wiener Neustadt. You can contact the representative at upway@prometa.at.

We collect the information you provide to us as follows:

• when you contact us;
• when you register as a user on the website or web app;
• when you use our services;
• when you apply to us; when you become a member of the association;
• or when you make a donation.

If you order paid services, we will also request your financial data, such as your preferred payment method and billing address. In this case, an external payment provider is used, and we do not have direct access to your information.

Due to the nature of the WebApp’s offering, it is possible that certain inferences about the health of specific users may be made. The user themselves determines whether they want to disclose information about their health status or not.

Provision and Use of our Website and WebApp

Usage for Information Purposes

You can visit our website to gather information about Upway and our services without disclosing your identity. Like any connection with a web server, the server on which we host the website and web app automatically logs and stores certain technical data for a limited period of time. This includes your IP address, device operating system, the date and time of your visit, and the type of browser used to access the website or web app.

Use of our WebApp

We operate the Upway WebApp (“WebApp”). When you register as a user on the WebApp, we collect the information you provide to us, such as your username (pseudonym), password, and email address. This includes your email address and other general personal data such as name and contact information, as well as personal information that you or other users enter, upload, generate, store, and modify while using the WebApp.

Donation Function

Web Analytics

External Website Resources

We include resources from external servers on our website. These resources may contain visible content (such as Google Maps).

When accessing these resources, the operator of the external servers may receive your IP address and/or certain incidental data that are necessary for the use of the servers operated by the external operator.

Note on the use of cookies

We use cookies, tags, and similar technologies on the website to provide you with the best possible user experience and to help us improve the website. Cookies are text files that are downloaded to your computer or mobile device when you visit a website or use an app.

Some of the cookies we use are necessary to provide certain functions of the website. We do not use cookies to analyze website usage or obtain information for website optimization purposes. We also do not use cookies for marketing purposes.

You can instruct your browser to refuse cookies or to prompt you before accepting a cookie. You can also delete cookies on your device using the relevant function in your browser.

Using our social media pages

On our social media pages, you will find posts about current developments at Upway as well as information about our services. The social media platforms collect and analyze usage data such as the number of visits and demographic information about the visitors of our company pages.

We receive evaluations from the social media platforms based on this data. These evaluations contain only aggregated or sufficiently anonymized data. Only the respective platform provider can identify you based on the collected usage data. Therefore, please refer to the privacy policies of the respective platform provider.

Using our newsletter

When you sign up for our newsletter or receive it as a member of the association or user of the WebApp, we collect the information you provide to us. This includes general personal data such as first name, last name, and email address.

You can also inform us at any time if you no longer wish to receive our newsletter. Please use the unsubscribe link at the end of the newsletter. By clicking on this link, we will no longer send you any newsletters in the future.

The purposes for which we process your personal data and the legal basis for such processing

We primarily process your personal data to inform you about our services and to fulfill our contractual and legal obligations, document and invoice our services.

In addition, we process your personal data for the following purposes:

• Responding to your inquiries and communicating with you;
• Processing your registration;
• Administering the membership of the association;
• Providing the website and the web app;
• Providing and enabling the use of the web app;
• Developing, improving, and providing the website and web app;
• Optimizing our posts on our social media company pages;
• Informing about new developments at Upway and new services (e.g., through our newsletter;
• where you can inform us at any time that you no longer wish to receive such information);
• Processing your job application;
• Complying with legal obligations; and
• Enforcing legal claims.

We have a legitimate interest in processing your personal data for the purposes mentioned above. Some processing activities are also necessary for us to fulfill our contractual obligations to you or our legal obligations (e.g., retention obligations). Based on this, we process your personal data to the extent that applicable data protection law requires a legal basis or justification for the processing activities in general or for specific processing activities.

How we store and protect your personal data

We only store your personal data to the extent and as long as necessary to fulfill the purposes described in this Privacy Policy or to fulfill legal obligations.

In order to ensure the integrity and confidentiality of personal data, we implement appropriate technical and organizational measures. Based on our risk assessment, we particularly implement access controls, authorization controls, and procedures for regularly reviewing, assessing, and evaluating the effectiveness of these measures.

Who we disclose your personal data to

In order to achieve the purposes described in this Privacy Policy, it may be necessary for us to disclose your personal data to other companies. These may include the following categories of recipients:

• external service providers;
• (if applicable) authorities and courts.

Location of Processing

Your Rights Regarding Your Personal Data

You have the following rights regarding your personal data:

• receive information about what personal data we store about you and how we process it;
• the right to receive or transfer a copy of your personal data in a common format;
• the right to correct your personal data;
• the right to delete your personal data; and the right to restrict the processing of your personal data.

Please note that there are legal requirements and exceptions for these rights. To the extent permitted by law, we may refuse your request to exercise these rights. You also have the right to lodge a complaint with the competent data protection supervisory authority.

How We Can Modify This Privacy Policy

We reserve the right to modify this privacy policy at any time, particularly if we make changes to our data processing practices or if new legal regulations become applicable. The current version of the privacy policy is available at www.upwayapp.com 

01.06.2023