This is the privacy policy of easy2taxfree GmbH; Windmühlgasse 25/7, 1060 Vienna, Austria (“easy2tax“, “Our Company” or “we”). This privacy policy will explain how our company uses the personal data in the context of (i) your use of our website under the domain https://easy2.tax (“Website”), (ii) your use of one of our easy2tax mobile Apps or easy2tax web Apps ( together “E2T App”), and/or (iii) your engagement of easy2tax to provide tax refund services either through an E2T App or by using the physical engagement form (“E2T Voucher”).

Topics:

1. What data do we collect?
2. How do we collect your data?
3. How will we use your data?
4. To whom do we transfer your data?
5. On what legal basis do we process your data?
6. How do we store your data?
7. For how long do we store your data?
8. What are your data protection rights?
9. Cookies
10. Changes to our privacy policy
11. How to contact us

1. What data do we collect?

Our Company collects the following data:

• Personal identification information to the extent provided by you (Profile picture, user name, selected password, name, last name, email address, date of birth, gender, permanent address, passport number and further details, nationality, phone number)
• Bank Account Details or any other given money transfer or refund details to the extent provided by you
• Geo-Location Data (From where are you using an E2T App
• Tax Free related Data (Where/When did you shop at our partner stores, The amount of your purchase, What good(s) did you purchase)
• Travel data (as far as required to determine the entitlement for a tax refund)
• Information on personal interests to the extent voluntarily provided by you (e.g. on tax free shopping, travel, etc.) through an E2T App

2. How do we collect your data?

You directly provide Our Company with most of the data we collect. We collect data and process data when you:

• Register for any of our products or services either through an E2T App or by using the physical E2T Voucher.
• Voluntarily complete a customer survey or provide feedback on our Website, an E2T App or on any of our message boards, products or via email.
• Fill out your physical E2T Voucher and send it to us.

Our Company may also receive your data indirectly from the following sources:

• Through your browser when you use or view our website via your browser’s cookies.
• Through cookies, trackers or settings in an E2T App.
• From the iOS AppStore or the Google Play Store when you download an E2T.
• From Google Analytics when you use or view our website via your browser’s cookies.

3. How will we use your data?

Our Company collects your data for the following purposes:

a. Contract Performance:

• Refunding/Transfer your Tax Refund
• Processing your E2T Voucher
• Manage your account

b. Improvement of our product and services:

• Optimize the content and usability on an E2T App or on our Website

c. Marketing:

• Personalization of content on an E2T App or on our Website
• Email you with special offers on other products and services we think you might like, as well as those of our partner companies.

NOTE: If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Our Company from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at [email protected].

CONSENT DECLARATION: By accepting this privacy policy, you provide your consent that easy2tax may process your personal data for the purposes set forth in section 3.c. above. This consent may be withdrawn at any time (see sections 8. and 11. below).

4. To whom do we transfer your data?

Our company may transfer your personal data to third parties as follows:

a. Transfers required for contract performance: 

• easy2tax will transfer Customer’s personal data including the name, tax free related data (relating to the good(s) purchased, the VAT and refund amount), bank account details or any other given money transfer or refund details to subsidiaries, retailers, tax and customs authorities and/or government departments, banks or payment services providers in order to fulfil its contractual obligations towards Customer, in particular to claim tax refunds and to effect payment of the VAT refund. This may include transfers of data outside the EWR in order to provide their services.
• easy2tax will transfer Customer’s personal data to IT service providers we use, such as Amazon Web Services.

b. Transfers in the legitimate interest of easy2tax or required to comply with legal obligations:

• easy2tax may transfer the Customers’ personal data for legal and regulatory reasons with our subsidiaries, retailer, tax and customs authorities and/or government departments to the extent permitted by applicable laws in order to ensure the Customers refund and/or for legal and regulatory requirements.
• easy2tax may transfer Customer’s personal data to, and also use the resulting information from, credit reference agencies and financial providers to prevent fraud.
• easy2tax may furthermore, if required, transfer personal data to its legal representatives and advisors, auditors for the performance of audits, courts, and public authorities, as well as collection agencies for debt collection.

c. Transfers for statistical analysis and marketing purposes:

If you agree, our Company will share your personal data, including name, address, gender, date of birth, nationality,      email address, and purchasing behavior (amount and type of goods purchased, time and location of purchase) as follows:

• With our easy2tax partner stores, i.e. retailers who are part of our network offering easy2tax services, so that they may offer you their products and services related to Tax Free shopping to you. The retailers may do so either through personalized communication via E-mail or through targeted advertisements on websites or apps, including our Website and an E2T App.
• With our easy2tax partner stores for statistical analysis.

CONSENT DECLARATION: By accepting this privacy policy, you provide your consent that easy2tax may transfer your personal data as set forth in section 4.c) above. This consent may be withdrawn at any time (see sections 8. and 11. below).

5. On what legal basis do we process your data?

The following legal bases for processing of personal data by Our Company apply:

The legal basis for all processing of personal data under section 3.a) above and all transfers of personal data under 4.a) above lies in the performance of the contract we have entered into with you or the fulfillment of any steps you may request (Art 6(1)(b) GDPR).

The legal basis for all processing of personal data under section 3.b) above and all transfers of personal data under 4.b) above lies in our overriding legitimate interest (Art 6(1)(f) GDPR) and/or the necessity to comply with legal obligations we are subject to (Art 6(1)(c) GDPR).

The legal basis for all processing of personal data under section 3.c) above and all transfers of personal data under 4.c) above lies in your consent you have provided herein (Art 6(1)(a) GDPR). This consent may be withdrawn at any time (see sections 8. and 11. below).

6. Processing and transfer of anonymized data

In addition to the processing and transfers of personal data as set forth under sections 3. and 4. above, easy2tax will also use certain categories of data on an anonymized basis to draft statistical reports on customer behaviour. This process will follow strict anonymization of all personal data and will only use data categories that do not allow the identification of a person, such as nationality, city, zip code, gender, age and purchasing behavior (amount and type of goods purchased, time and location of purchase). Such statistical reports, which are clear from any personal information, may be shared with third parties such as retailers or other trade partners of easy2tax.

7. How do we store your data?

Our Company securely stores your data at our AWS (Amazon Web Services) Servers, located either in the U.S.A. or within the European Union.

8. For how long do we store your data?

Our Company will keep your personal information related to tax refund processes for 7 years due to legal requirements. Any data not related to tax refund processes and for which retention is not required under statutory retention obligations will be deleted within 3 years after the business relation is terminated.

9. What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights.

Every user is entitled to the following:

The right to access – You have the right to obtain confirmation as to whether and what kind of personal data we store and request copies of such personal data. 

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Our Company erase your personal data, if the legal basis for storing it was your consent and you have withdrawn such consent, and unless storing it is required to comply with legal obligations.

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, if the legal basis for storing it was your consent and you have withdrawn such consent, unless keeping it unrestricted is required to comply with legal obligations.

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you.

The right to complain – You have the right to file a complaint with the competent supervisory authority.

Any request will need to be accompanied by sufficient information for us to determine the identity of the user concerned. If you make a request, we have one month from receipt of your request and all required information to respond to you. If you would like to exercise any of these rights, please contact us under our contact details below.

10. Cookies

What are Cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our Website and an E2T App, including:

• Keeping you signed in
• Understanding how you use our website and E2T App
• Advertising
• Preferences of your Account
• Personalize the content you see
• Location based information

What types of cookies do we use?

There are a number of different types of cookies, however, our Website and E2T App uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Our Company uses these cookies to collect information about your visit to our website and/or an E2T App, the content you viewed, the links you followed and information about your browser, device, and your IP address. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
• Account related – If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.
• Login related – We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
• Email newsletters related – This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
• Forms related – When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
• Site preferences – In order to provide you with a great experience on this site or on an E2T App we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• Site preferences – In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
• This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
• Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
• From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
• We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, Instagram and LinkedIn, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

CONSENT DECLARATION: Unless disabled through your browser setting, by accepting this privacy policy or by clicking “I accept” in the cookie banner on our Website, you provide your consent that easy2tax may process your personal data collected through cookies as set forth above. This consent may be withdrawn at any time (see sections 8. and 11.).

11. 11.Changes to our privacy policy

Our company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 6th November 2019.

12. 12.How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us:

easy2taxfree GmbH; Windmühlgasse 25/7, 1060 Vienna, Austria

Email us at: [email protected]