Data Privacy Policy

The entity responsible for processing your personal data on our website is:

Commend International GmbH (hereinafter referred to as “we”/“our”)
Saalachstrasse 51, 5020 Salzburg, Austria
Telephone +43 662 856 225
E-mail: office(at)commend.com

You have the opportunity to participate in online surveys on our website. It’s a quick-and-easy way to share your thoughts and provide feedback on our products.

If you wish a response to your feedback, you can fill in your contact details (name, e-mail address, telephone number, company and optionally your address) on the feedback form.

In this case, the contact details you provide, as well as your message, are processed for the purpose of performing (pre-)contractual steps pursuant to Article 6(1)(b) GDPR.

On our website you also have the opportunity to sign up for training courses and events. When you do so, we need the following details: 

• First name, last name
• Company affiliation
• E-mail address
• Number of participants/seats to be reserved
• optionally your address, telephone number and remarks.

We will process your data exclusively for the purpose of organising the booked training sessions or events, and for providing attendance certificates etc., as required.

The processing of your data (name, company affiliation, e-mail, number of participants) is required for us to organise the training sessions or events, as provided for in Article 6(1)(b) GDPR.

You have the opportunity to apply for a job at Commend International GmbH and associated regional sales organisations via our website. To do so, enter your name., e-mail address and message in the online application form. You may also upload files (such as your CV).

We will process your data exclusively for the purpose of processing your application pursuant to Article 6(1)(b) GDPR).

We have linked our website to Hubspot, a Customer Relationship Management tool. This application will collect personal data that you have provided in order to use cLibrary, receive our newsletter or contact us (section 2.1 to 2.4 above).

When you consent to the use of cookies or similar trackers, the details of your surfing behaviour on the website will be forwarded to the Hubspot tool. For more details on our tracking applications and on the information collected, see section 4 as well as our Overview of Cookies.

Hubspot uses the data it receives to register you as a “contact” within the CRM tool and to manage your communication with us. In doing so, Hubspot automatically assigns you to your local Commend marketing organisation. New information allows us to offer you targeted services. If you have subscribed to our newsletter (see section 2.2 above), this allows us to adjust our advertising to your requirements.

We process your data using Hubspot based on our legitimate interests (pursuant to Article 6(1)(f) GDPR) in order to ensure the efficiency of our business communication, take targeted marketing measures and offer you a personalised service where possible.

Hubspot is an application of Hubspot Germany GmbH, Am Postbahnhof 17, 10243 Berlin, Germany, which works on our behalf as a Processor pursuant to Article 28 GDPR. Hubspot’s processing is subject to the Processor Agreement that can be accessed at https://legal.hubspot.com/de/dpa.

Hubspot Germany GmbH is a subsidiary of Hubspot Inc, which is headquartered at 25 First Street, Cambridge, Massachusetts MA 02141, USA. For this reason, some data may also be transferred to Hubspot’s parent company. Hubspot.Inc is a member of the Data Privacy Framework (“DPF”) between the USA and the EU. The transfer of your data to the USA is therefore legitimate pursuant to an adequacy decision of the Commission in accordance with Article 45 GDPR.

Infrastructure and Data Hosting Location: European Union / Germany

The data of customers and interested parties stored in Hubspot (name, address, telephone number, e-mail, company) are shared with our second Customer Relationship Management tool, Salesforce, on a regular basis.

Salesforce also uses the data to register you as a contact. This tool allows us to track the progress of business relationships and various sales projects in a clearly structured way.

This means we will process your data for the purpose of our legitimate interest pursuant to Article 6(1)(f) GDPR to ensure the efficiency of our marketing structure and to make our customer projects easy to organise and manage.

Salesforce is an application of Salesforce.com Germany GmbH, Erika-Mann Strasse 31, 80636 Munich, Germany, which works on our behalf as a Processor pursuant to Article 28 GDPR. Salesforce’s processing is subject to a Processor Agreement.

Salesforce.com Germany GmbH is a subsidiary of Salesforce Inc, which is headquartered at 415 Mission Street, San Francisco, California CA 94105, USA. For this reason, some data may also be transferred to Salesforce’s parent company. Salesforce Inc is a member of the Data Privacy Framework (“DPF”) between the USA and the EU. The transfer of your data to the USA is therefore legitimate, based on an adequacy decision of the Commission pursuant to Article 45 GDPR.

Infrastructure and Data Hosting Location: European Union / Sweden

Some cookies require your consent before they can be used on your device; other cookies may be used without your express consent, as they are technically necessary for rendering our services (“necessary / essential cookies”).

Necessary cookies are required for the website to function properly, They can therefore not be disabled on your systems. Cookies are normally created only in response to an action on your part equivalent to requesting a service: for example, configuring data privacy settings, logging into a user account or filling in an online form. You can set your browser to block these cookies or to notify you about them. If you do so, some parts of the website will not function properly. The data are processed for the purpose of ensuring data security, preventing misuse and optimising the website. The processing of the data therefore serves our legitimate interests as defined in Article 6(1)(f) GDPR.

We will use other cookies (statistics and marketing cookies) on our website only subject to your express prior consent pursuant to Article 6(1)(a) GDPR. When you use the website for the first time, you can either accept all cookies by clicking the ‘Accept all’ button in general or select or deselect each individual type separately and confirm with the ‘Accept selected’ button. If you do not select any additional cookies, no cookie-based services requiring consent will be loaded. You can change the setting at any time. To do this, click on the icon (shield) in the bottom left-hand corner of the page (always visible).

Visitors and Users from Austria: As mentioned above, data processing is necessary for the purposes of data security measures, to prevent misuse and to optimise the website and is therefore based on our legitimate interests, also in accordance with § 165(3) Austrian Telecommunications Act (TKG 2021). We only use all other cookies (statistics and marketing cookies) on our website on the basis of your prior express consent, also in accordance with § 165(3) Austrian Telecommunications Act (TKG 2021).

Visitors and Users from Switzerland: New Swiss Data Protection Act (nDSG) – The legal basis for processing personal data by means of cookies is Article 6 nDSG and Article 6(1)(f) GDPR.

Specific details about which cookies are activated for which purposes can be found in the Cookie List.

If you want to block or delete cookies on your computer, you can do so via your browser’s configuration settings. As for managing cookies, most browsers offer an option to accept or decline all cookies, or only specific ones. You also have the option of being prompted every time a web page wants to store a cookie on your system. The methods for managing and deleting cookies may vary depending on your browser. To find out how to manage or delete cookies in your browser, we suggest you check your browser’s help function or visit https://www.aboutcookies.org. There you will find step-by-step instructions on how to manage cookies in the most common browsers.

If you delete all of your stored cookies, you will have to repeat the opt-out process when you visit our website again. This also applies if you are visiting our website using a different computer.

Note that if your local Internet security settings are set to a high level where cookies are blocked, we will not be able to process your opt-out request. In that case, a message to that effect will be shown. You can then re-try the opt-out procedure with less severe security settings.

You can change the settings set at the beginning of the consent banner at any time. To do this, click on the icon (shield) in the bottom left-hand corner of the page (always visible).

We will share your personal data as necessary with the following third-party service providers (Processors):

• IT service providers and/or providers of data hosting or data processing or similar services;
• other service providers as well as providers of tools and software solutions that likewise support us in rendering our services and act on hour behalf (including providers of marketing tools, marketing agencies and communication service providers).

All of our Processors will process your data only on our request and based on our instructions so as to enable us to render the above-mentioned services.
Furthermore, we will share your personal data as necessary with the following recipients:

• any third parties involved in the fulfilment of our obligations to you (e.g. payment service providers);
• third parties to the extent required to serve our legitimate interests (e.g., chartered accountants/auditors, insurance providers in case of an insurance claim, legal representatives if required, etc.)
• official authorities and other public institutions, to the extent required by law (e.g., financial authorities, etc.).

Inasmuch as we or third-party services commissioned by us process your data in a country outside the European Union (EU) or the European Economic Community (EEC), this processing is limited to the extent necessary for us to fulfill our (pre-)contractual obligations, subject to your consent and based on a legal commitment, or in order to serve our legitimate interests. We have implemented suitable and appropriate measures to guarantee conformity with data protection regulations when transferring your data to a required third country (e.g., adequacy decisions, binding Corporate Rules or standard data protection clauses). We will, upon your request, provide you with a copy of these adequate guarantees regarding the processing of your data in third countries by ourselves or third parties. Where no sufficient guarantee exists regarding the transfer of data, the data may be transferred in individual cases based on your voluntary consent.

We only store your personal data for as long as is necessary for the purpose for which your data was collected or for as long as we are legally obliged to store your data.

In the event that personal data concerning you is processed on the basis of your express consent, we will store your data until you revoke your consent to us or, if no revocation of your consent is made, for a maximum storage period determined by us in accordance with the principles of proper data processing.

You have the right to information, rectification, erasure and restriction of processing of your personal data, as well as the right to data portability.

Furthermore, you have the right to withdraw any previously given consent to the processing of your personal data. The legitimacy of the processing of personal data up to the time of your withdrawal will remain unaffected by the withdrawal.

You have the right to object to the processing of your personal data.

Should you have reason to assume that the processing of your data might violate data protection laws or that your right to data privacy has been otherwise violated, please feel free to notify us about your concerns. To do so, please contact us using the contact options provided in point 1. In addition, and irrespective of any prior notification submitted to us, you have the right to lodge a complaint with the appropriate supervisory authority.

List of authorities in EU member states

Switzerland