Team Freshwords (hereinafter also „we“) takes the protection of your personal data very seriously.

We treat your personal data confidentially and in accordance with the statutory data protection regulations (GDPR, TKG 2003) as well as this policy. This policy informs you about how we collect, process, and use personal data.

1. Name and Contact Details of the Controller

The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) and other data protection provisions is:

Freshwords e. U.
Proprietor: Dr. Stefan Müller
Redtenbachergasse 57/26, 1160 Vienna, Austria

2. Definitions

This privacy policy is based on the terminology used by the European legislator and regulator when issuing the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand. To ensure this, we would like to explain the terminology used in advance. In this privacy policy, we use the following terms, among others:

• Personal Data: Any information relating to an identified or identifiable natural person (hereinafter „data subject“).
• Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

3. What Data is Processed and from What Sources?

We collect personal data, for example, in the course of the following activities:

Newsletter registration, inquiries via the contact form, inquiries via email, inquiries via telephone, information provided in person (e.g., business cards).

Freshwords uses personal data, for example, for the following purposes:

Fulfillment of contractual services, fulfillment of legal obligations, to enable the use of certain functions, to deliver requested goods or services, for the administration of job applications. Your personal data will neither be sold to third parties nor otherwise marketed.

Personal data includes, for example: Your personal details (name, address, contact information)

Furthermore, this may also include the following data:

• Data from the fulfillment of my contractual obligations (e.g., invoice data)
• Advertising and sales data
• Documentation data (log files, protocols, etc.)
• Registry data
• Image data (application photos)
• Information from your electronic communications (e.g., apps, cookies, email, etc.)
• Processing results that we generate ourselves
• Data for fulfilling legal and regulatory requirements

If you send personal data via email—and thus outside of this website—we cannot guarantee a secure transmission and the protection of your data. We recommend that you never transmit confidential data unencrypted via email.

4. Specific Purposes and Legal Bases for Data Processing

We process personal data for the following purposes and on the basis of the following legal grounds:

a) Data Processing for Journalistic Purposes

Freshwords e. U. processes personal data as part of its activities as a PR consultant. This includes the research, creation, and publication of journalistic content.

• Purposes: Fulfilling the public information mandate, exercising the freedom of expression and information.
• Legal Basis: The processing is based on Art. 6(1)(f) GDPR (safeguarding legitimate interests) in conjunction with Art. 85 GDPR and § 9 of the Austrian Data Protection Act (DSG) concerning processing for journalistic purposes („media privilege“). The legitimate interest lies in exercising the freedom of the press and informing the public.

b) Data Processing in the Context of Customer Relationships and Contract Execution

We process personal data that you provide to us as a customer or client.

• Purposes: Initiation, conclusion, execution, and settlement of contracts and orders; communication with customers and clients; invoicing.
• Legal Basis: The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR). If consent is required (e.g., for certain marketing activities), the processing is based on your consent (Art. 6(1)(a) GDPR).

c) Data Processing When Visiting Our Website

When you visit our website, your IP address, the start and end of the session are recorded for the duration of that session. Each time our website is accessed, data and information from the computer system of the calling computer may be automatically collected (so-called server log files). The following can be recorded: browser type and version, operating system used, referrer URL (the previously visited page), hostname of the accessing computer (IP address), time of the server request.

• Purposes: Ensuring a smooth connection to the website, ensuring comfortable use of our website, evaluating system security and stability, and for other administrative purposes.
• Legal Basis: The processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in the technically error-free presentation and optimization of our website.

Unless otherwise specified below, this data will not be further processed by us. This anonymous data is stored separately from any personal data you may have provided and thus does not allow any conclusions to be drawn about a specific person. It is evaluated for statistical purposes in order to optimize our website and our offers.

d) Contact

If you contact us by email or subscribe to the „Fresh“ Newsletter, the personal data you transmit will be stored.

• Purposes: Processing your inquiry and contacting you.
• Legal Basis: The data is processed for the performance of pre-contractual measures or for contract fulfillment (Art. 6(1)(b) GDPR) or on the basis of our legitimate interest in responding to your request (Art. 6(1)(f) GDPR).

Your provided data will be stored by us for six months in case of follow-up questions. This constitutes a legitimate interest within the meaning of the GDPR. We do not share this data without your consent.

5) Use of Google Analytics

We use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter „Google“. Google Analytics uses so-called „cookies“, text files that are stored on your computer and thereby enable an analysis of your use of the website.

The information generated by these cookies, such as the time, place, and frequency of your website visit including your IP address, is transmitted to Google in the USA and stored there. We use Google Analytics with an IP anonymization feature. In this case, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thus anonymized.

Google will use this information to evaluate your use of my site, to compile reports on website activities for us, and to provide other services related to website and internet use. Google may also transfer this information to third parties if required by law or if third parties process this data on behalf of Google.

According to its own statements, Google will in no case associate your IP address with other Google data. You can prevent the installation of cookies by setting your browser software accordingly; in this case, you may not be able to use all functions of this website to their full extent.

Furthermore, Google offers a deactivation option for the most common browsers, which gives you more control over what data is collected and processed by Google. If you activate this option, no information about the website visit will be transmitted to Google Analytics. However, activation does not prevent information from being transmitted to us or to other web analysis services we may use. For more information on the deactivation option provided by Google and how to activate it, please use the following link: https://tools.google.com/dlpage/gaoptout?hl=en

6) Cookies

This site uses cookies to recognize repeated use of the offer by the same user/internet connection owner. Cookies are small text files that your internet browser stores on your computer. They serve to optimize this website and its offers. These are mostly so-called „session cookies“, which are deleted after the end of your visit.

However, some of these cookies provide information to recognize you automatically. This recognition is based on the IP address stored in the cookies. The information obtained in this way serves to optimize my offers and to provide you with easier access to my site.

You can prevent the installation of cookies by setting your browser accordingly; in this case, you may not be able to use all functions of this website to their full extent.

7. Recipients or Categories of Recipients of Personal Data

Within Freshwords e. U., only those departments that need your data to fulfill our contractual and legal obligations or to process your request will have access to it.

Your data is generally not passed on to third parties unless we are legally obliged to do so (e.g., to tax authorities), the data transfer is necessary for the execution of the contractual relationship with you (e.g., to payment service providers), or you have given us your express prior consent.

Freshwords often works with subcontractors. If we use external service providers (processors pursuant to Art. 28 GDPR) who process personal data on our behalf (e.g., for IT services, website hosting), we ensure through corresponding contractual agreements that the protection of your data is guaranteed. As part of our journalistic activities, information may be published under certain circumstances, whereby a balance is always struck with the rights of the data subjects.

8. Transfer of Personal Data to Third Countries

A data transfer to entities in states outside the European Union (so-called third countries) only takes place if

• it is necessary for the execution of your orders (e.g., for certain international research),
• it is required by law, or
• you have given us your consent.
  Should a transfer to a third country occur, we will ensure that an adequate level of data protection is guaranteed (e.g., through EU Standard Contractual Clauses or adequacy decisions of the EU Commission).

9. Storage Period

We process and store your personal data only for as long as it is necessary to achieve the respective storage purpose or as provided for by statutory retention periods.

• Data for journalistic purposes: Personal data processed for journalistic purposes may be stored longer due to archival interest in the public interest and to protect the freedom of expression and information. The necessity of storage is regularly reviewed.
• Data from customer relationships: Personal data processed in the context of customer relationships and orders are stored for the duration of the business relationship and beyond, in accordance with statutory retention and documentation obligations. As per your specification, data will only be stored for a limited time if the order requires it, whereby statutory minimum retention periods are always observed.
• Server log files: Are generally deleted after a short time, unless longer storage is necessary for security reasons (e.g., to investigate cases of misuse).

Once the purpose of storage no longer applies or the statutory retention period expires, the personal data will be routinely blocked or erased in accordance with legal provisions.

10. Your Rights as a Data Subject (Data Subject Rights)

You have the right to receive information about your personal data stored by us at any time. You also have the right to rectification, blocking, or, apart from the mandatory data storage for business processing, erasure of your personal data. Please contact our data protection manager for this purpose.

So that a block on data can be considered at any time, this data must be kept in a suppression file for control purposes. You can also request the erasure of the data, provided there is no legal archiving obligation. If such an obligation exists, we will block your data upon request.

You can make changes or revoke consent by notifying us accordingly with effect for the future. Furthermore, you have the right to rectification of data as well as to restriction of processing, to data portability, and to lodge a complaint with the Austrian Data Protection Authority.

Important Note on Data Subject Rights in Journalistic Processing:

Please note that the above-mentioned data subject rights may be restricted in accordance with Art. 85 GDPR in conjunction with § 9 of the Austrian Data Protection Act (DSG) when personal data is processed for journalistic purposes. This serves to protect the freedom of expression and information. A balancing of interests is carried out on a case-by-case basis.

11. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The competent supervisory authority in Austria is:

Austrian Data Protection Authority (Österreichische Datenschutzbehörde)
Barichgasse 40-42
1030 Vienna

12. Data Security

We take appropriate technical and organizational security measures (TOMs) to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. However, absolute security cannot be guaranteed for data transmission over the internet (e.g., when communicating by email).

13. Image Credits

With special thanks to all creators.
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14. Timeliness and Amendment of this Privacy Policy

This privacy policy is currently valid and is as of January 2026.
Due to the further development of our website and offers thereon or due to changed legal or official requirements, it may become necessary to amend this privacy policy. The current privacy policy can be accessed and printed by you from the website at any time. We recommend that you regularly inform yourself about the content of our privacy policy.