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Privacy Policy

Version 1.1 of 3 September 2026

Protecting personal data matters to me. This policy describes what data is processed when you visit and use this service, for what purpose and on what legal basis. It fulfils the information obligations under Art. 13 and 14 of the General Data Protection Regulation (GDPR) as well as the requirements of the Austrian Data Protection Act (DSG) and sec. 165 of the Austrian Telecommunications Act 2021 (TKG 2021).

1. The essentials first

  • No analytics, tracking or advertising service is used.
  • Your entries stay on your own device. There is no account and no login.
  • Payments are handled by Lemon Squeezy. Card or account details are never visible to the provider.
  • Personal data is neither sold nor passed on to third parties for advertising purposes.

2. Controller

The controller within the meaning of Art. 4 (7) GDPR is:

Robert Thalhammer
Grabengasse 13/3/2
2630 Ternitz
Niederösterreich, Austria
E-mail: info@fussfessel-hilfe.at

No data protection officer has been appointed because the statutory conditions of Art. 37 GDPR are not met. All data protection enquiries go directly to the address above.

3. Hosting and servers

This website is hosted by IONOS SE, Elgendorfer Strasse 57, 56410 Montabaur, Germany. The servers are located in Germany and therefore within the European Union. A data processing agreement pursuant to Art. 28 GDPR is in place with IONOS.

4. Server log files

When the website is accessed, data transmitted by the browser is automatically stored in server log files:

  • IP address of the requesting device
  • date and time of access
  • name and URL of the file retrieved
  • volume of data transferred and notification of successful retrieval
  • browser type, browser version and operating system
  • where applicable, the previously visited page (referrer)

This data serves technical operation, troubleshooting and the prevention of attacks. The legal basis is Art. 6 (1) (f) GDPR. Log files are generally deleted automatically after no more than seven days. This data is not merged with other data sources.

5. No analytics or tracking services

No analytics, tracking or advertising services are used on this website. Neither Google Analytics nor Facebook pixels, advertising networks or comparable services are in use. No profiling and no cross-device recognition takes place.

6. Cookies

No cookies are set — neither our own nor those of third parties. Only strictly necessary entries in the browser's local storage are used: the entry that allows the generated file to be retrieved again (seven days at most) and the confirmation of the terms of use (24 hours at most). Both serve only the function requested by the user; no consent is required for them under sec. 165 (3) TKG 2021. Both entries can be deleted immediately at any time via the button in the assistant. A consent banner is therefore not required.

7. Data that stays on your own device

All entries made in the assistant are processed exclusively in the browser on your own device. The finished PDF file is generated locally in the browser. No input data is transmitted to the provider or stored there.

So that the generated file can be retrieved again, an entry is created in the browser's local storage (localStorage) and automatically deleted after seven days at the latest. In addition, confirmation of the terms of use is stored locally for a maximum of 24 hours. A button in the assistant allows this local data to be deleted immediately at any time.

8. Special note on criminal-law data

The information entered in the assistant may contain data relating to criminal convictions and offences within the meaning of Art. 10 GDPR. That is precisely why the service is built so that this information never leaves your own device: it is processed exclusively locally in the browser, is not transmitted to the provider and is not stored there.

The provider therefore never obtains knowledge of the content of the completed forms. Anyone who passes on the generated PDF file decides to do so entirely on their own.

9. Payment processing (Lemon Squeezy)

Paid services are processed via Lemon Squeezy, operated by Lemon Squeezy LLC, 5900 Balcones Drive, Suite 100, Austin, TX 78731, USA. Lemon Squeezy acts as Merchant of Record, i.e. it is the contracting party for the payment transaction and handles the tax processing.

Payment data (in particular card or account details) is processed exclusively by Lemon Squeezy and is at no time visible to the provider. Only the information required to fulfil the order is transmitted to the provider: order number, product, time of purchase, amount, country and e-mail address.

The legal basis is Art. 6 (1) (b) GDPR (performance of a contract) and Art. 6 (1) (c) GDPR for tax retention. The transfer to the USA is based on the Standard Contractual Clauses pursuant to Art. 46 (2) (c) GDPR. Lemon Squeezy's privacy policy applies in addition.

10. Purchase data and Art. 10 GDPR

The contents of the completed forms never reach the provider. Through the payment process, however, the provider does learn that a particular e-mail address purchased this product. Because that permits an inference about pending or concluded criminal proceedings, this data set is given special protection:

  • It is used exclusively to process the purchase and to meet tax obligations (Art. 6 (1) (b) and (c) GDPR).
  • It is not used for advertising, analysis, statistics or profiling and is not passed on to third parties.
  • No permanent purchase list is maintained. Only the records required for tax purposes under sec. 132 BAO are retained; any further records are deleted once the purchase has been completed.
  • Only the controller has access.
  • Deliberately, only the neutral designation "ROBSCHMAN" appears on the card or account statement – no indication of the product's content.

11. Translation function

A translation function can be called up on the website which uses the MyMemory service of Translated S.r.l., Via Indonesia 23, 00144 Rome, Italy. The service is only loaded after express consent. The text section to be translated is transmitted to Translated S.r.l. (established in the EU, no third-country transfer); the provider of this website does not receive it. Please do not enter any personal or criminal-law-related information into the translation function. The legal basis is Art. 6 (1) (a) GDPR (consent). Without consent, no connection is established.

12. Contact form

A contact form is available on the website. What is transmitted is the message entered there and the sender's address; any further details are optional. The message is delivered to the provider's mailbox and processed there like an ordinary e-mail. No third-party form service is embedded.

The legal basis is Art. 6 (1) (b) GDPR for enquiries relating to a contract and Art. 6 (1) (f) GDPR for other enquiries. Enquiries are deleted once they have been finally dealt with.

Important: the form is intended for general questions about the procedure and the product. Please do not submit any information about criminal proceedings, convictions or health data through it. Such information is not needed in order to answer your question.

13. Contact by e-mail

Anyone who makes contact by e-mail thereby transmits their e-mail address and the content of the message. This information is used exclusively to process the enquiry.

The legal basis is Art. 6 (1) (b) GDPR for enquiries relating to a contract and Art. 6 (1) (f) GDPR for other enquiries. E-mail traffic is processed by the respective e-mail provider, who acts as a processor in this respect. Enquiries are deleted once they have been finally dealt with. Anything kept longer is kept only because a statutory retention obligation applies — which concerns solely business correspondence that serves as an accounting record and must be retained for seven years pursuant to sec. 132 of the Austrian Federal Fiscal Code (BAO).

14. No automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.

15. Is providing data mandatory?

  • The details requested during the payment process are required in order to make a purchase; without them the purchase cannot be processed and no invoice can be issued.
  • Simply visiting the website is possible without providing any personal data.

There is no statutory obligation to provide personal data.

16. Retention periods

Personal data is stored only for as long as is necessary for the respective purpose or as required by statutory retention obligations. The specific periods are stated with the individual processing operations above. In addition:

  • server log files: seven days at most, in so far as the provider keeps them itself
  • e-mail enquiries: until the matter has been finally dealt with
  • records of consent given: for the duration of the accountability obligation under Art. 5 (2) GDPR
  • accounting and invoicing documents: seven years pursuant to sec. 132 BAO

17. Recipients and transfers to third countries

Personal data is not sold and is not passed on to third parties for advertising purposes. Disclosure takes place only to the service providers and payment services named above and to public authorities where there is a statutory obligation to do so, as well as to the tax adviser and bank to the extent necessary.

Where data is transferred to third countries outside the EU and the EEA, this takes place only on the basis of an adequacy decision of the European Commission or the Standard Contractual Clauses pursuant to Art. 46 (2) (c) GDPR. The applicable basis is stated with each affected processing operation above.

18. Rights of data subjects

Under the GDPR you have the following rights:

  • Access (Art. 15 GDPR): which data is being processed
  • Rectification (Art. 16 GDPR): to have inaccurate data corrected
  • Erasure (Art. 17 GDPR): to have data deleted, unless a retention obligation applies
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR): to receive the data in a common format
  • Objection (Art. 21 GDPR) to processing based on a legitimate interest
  • Withdrawal of consent (Art. 7 (3) GDPR), at any time and with effect for the future

An informal message to the e-mail address above is sufficient to exercise these rights. A reply will be given within the statutory period of one month. To prevent misuse, proof of identity may be requested in case of doubt.

Separate notice of the right to object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out on the basis of a legitimate interest under Art. 6 (1) (f) GDPR. Where your data is processed for direct marketing purposes, you may object at any time and without giving reasons; your data will then no longer be processed for that purpose. An informal objection to the e-mail address above is sufficient.

19. Right to lodge a complaint

Anyone who believes that the processing of their data infringes data protection law may lodge a complaint with the supervisory authority:

Austrian Data Protection Authority (Österreichische Datenschutzbehörde)
Barichgasse 40-42, 1030 Wien, Austria
Phone: +43 1 52 152-0 · E-mail: dsb@dsb.gv.at · www.dsb.gv.at

20. Data security

The website is delivered exclusively over an encrypted TLS/HTTPS connection. Accounts are secured with strong, individual passwords and — where available — two-factor authentication. On the controller's side, only the controller has access. In addition, the service providers named above have access within the scope of their respective services, bound by confidentiality and — where they act as processors — by a contract pursuant to Art. 28 GDPR.

21. Changes to this privacy policy

This privacy policy is updated whenever the processing operations change — for example when a service is added or removed. The version published on this page is the one that applies.

Controller

Robert Thalhammer
Grabengasse 13/3/2
2630 Ternitz
Niederösterreich, Austria
E-mail: info@fussfessel-hilfe.at

Last updated: 3 September 2026