Legal

Privacy Policy

1. Data Protection at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. Detailed information on data protection can be found in our privacy policy set out below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section "Information on the Controller" in this privacy policy.

How do we collect your data?

Some of your data is collected when you provide it to us. This may, for example, be data that you enter into a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

Analysis Tools and Third-Party Tools

When you visit this website, your browsing behaviour may be statistically analysed. This is done mainly with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. General Information and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the Controller

The controller responsible for data processing on this website is:

Avelios Medical GmbH
Ridlerstr. 39
80339 München
Germany
Email: info@avelios.com

Data Protection Officer

Lukmann Consulting GmbH
Dipl. Ing. Walter Lukmann
Packerstraße 131a
A-8561 Söding
Telephone: +43 660 60 888 01
Email: service@dsgvoschutzteam.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a justified request for deletion or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place once these reasons no longer apply.

Data Storage and Deletion

We store your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by statutory retention periods. This applies in particular to:

Contract-related data: Data is stored until the contract has been fully processed and thereafter in accordance with statutory retention periods.

Marketing data: This data is stored until you withdraw your consent or storage is no longer necessary for us.

After these periods have expired, your data will be deleted in accordance with Art. 17 GDPR, unless there are other legal obligations requiring further storage.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data pursuant to Art. 9(1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your terminal device (e.g. via device fingerprinting), data processing is additionally based on Section 25(1) TDDDG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR.

Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Information on Data Transfers to the USA and Other Third Countries

We use, among other things, services from providers based in the USA. When these services are active, your personal data may be transferred to and processed in the USA.

The European Commission has adopted an adequacy decision for the USA (EU-US Data Privacy Framework, DPF). According to this decision, a data transfer is permitted if the recipient is certified under the DPF. In addition, where necessary, we conclude EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). Information on the individual recipients and the respective legal basis for the transfer can be found in the relevant sections of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the disclosure, or if another legal basis permits the disclosure. When using processors, we only pass on our customers' personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint controllership agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, Correction and Deletion

Within the framework of the applicable legal provisions, you have the right at any time to receive information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing, and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us about this at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.

If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.

If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

3. Hosting

We host the content of our website with the following provider:

Vercel

The provider is Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA (hereinafter Vercel). When you visit our website, Vercel collects various log files including your IP address, date and time of access, the URL accessed, the referrer URL and browser and operating system information.

Vercel is a platform for deploying and hosting websites. Delivery takes place via a global server network; data may also be processed on servers outside the EU. The personal data collected on this website is processed via the hoster's servers. This also applies to the data from our contact and application forms, which is forwarded via Vercel to the respective services (HubSpot, Ashby). Vercel does not set any cookies when hosting our website.

Vercel is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the secure, fast and reliable provision of our website.

For details, please refer to Vercel's privacy policy: https://vercel.com/legal/privacy-notice.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. The company is also certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be found at: https://www.dataprivacyframework.gov/.

Data Processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

4. Data Collection on This Website

Cookies

Our website uses so-called "cookies". Cookies are small data packets and do not cause any damage to your terminal device. They are stored on your terminal device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites.

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them. Other cookies can be used to evaluate user behaviour or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process or to provide certain functions requested by you (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR and Section 25(2) TDDDG, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be withdrawn at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

Consent Management

When you first visit our website, we ask whether you agree to non-essential services. Until you make a decision, and after a rejection, no non-essential scripts are loaded and no cookies are set.

To store your decision, we save the entry "avelios-cookie-consent" in your browser's local storage (localStorage). It contains only the information whether you have agreed or declined. This entry is technically necessary to respect your decision. The legal basis is Section 25(2) No. 2 TDDDG and Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR.

You can change your decision or withdraw your consent with effect for the future at any time.

Contact Form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. The forms on our website are processed via HubSpot (see section "HubSpot"). Beyond this, we do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

HubSpot

The provider is HubSpot Ireland Limited, One Dockland Central, Guild Street, Dublin 1, Ireland (hereinafter HubSpot). We use HubSpot to process enquiries via the forms on our website, to send our newsletter and to manage customer, prospect and partner contacts (CRM).

When you fill out a form on our website, your details are transmitted to HubSpot and stored there. Depending on the form, this includes in particular first name, last name, business email address, your concern and your message. For partner enquiries, this also includes position, company, website, location and information about your company or product. The legal bases correspond to those in the section "Contact Form".

After your consent, our website loads a script from HubSpot that sets cookies (hubspotutk, __hstc, __hssc, __hssrc). HubSpot uses these to analyse the use of our website and to assign form enquiries to your visit. If you submit a form after giving your consent, the identifier from the hubspotutk cookie is also transmitted so that HubSpot can link your contact with your previous page visits. The legal basis is your consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG). Consent can be withdrawn at any time.

For details, please refer to HubSpot's privacy policy: https://legal.hubspot.com/privacy-policy.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. The company is also certified under the "EU-US Data Privacy Framework" (DPF).

Data Processing

Enquiries by Email, Telephone or Fax

If you contact us by email, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The data you send us via contact enquiries will remain with us until you ask us to delete it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Ashby

You can apply via the application form on our website. The data entered there (e.g. contact details, CV, cover letter) is transmitted to Ashby, a service of Ashby, Inc., 548 Market St PMB 397006, San Francisco, CA 94104, USA, and stored there on our behalf. We process this data exclusively for the purpose of carrying out the application process. The legal basis is Art. 6(1)(b) GDPR.

If no employment relationship is established, we will delete your data no later than six months after the conclusion of the process.

For details, please refer to Ashby's privacy policy: https://www.ashbyhq.com/privacy. The company is certified under the "EU-US Data Privacy Framework" (DPF). We have concluded a data processing agreement (DPA) with Ashby.

Microsoft Clarity

Our website uses Microsoft Clarity, a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, which helps us to better understand user behaviour and to optimise the user-friendliness of our website. Clarity uses cookies and other technologies to collect data about user behaviour on our website, including information about interactions with our website, the time spent on individual pages and the frequency of visits.

The data collected by Microsoft Clarity is anonymised and is not used to identify individual persons. The data may be transferred to and stored on servers in the USA. Microsoft has joined the EU-US Data Privacy Framework, which ensures an adequate level of protection for personal data.

Purpose of Data Processing

The information collected with Microsoft Clarity helps us to improve the user-friendliness of our website by understanding how users interact with our website. This data is used exclusively for analysis purposes and not to create user profiles or for other purposes unrelated to the improvement of our website.

Legal Basis for Data Processing

The data is processed on the basis of your consent pursuant to Art. 6(1)(a) GDPR. You can withdraw your consent at any time by adjusting the cookie settings in your browser or by contacting us using the contact information below.

How Can You Deactivate Data Collection?

You can prevent the collection of your data by Microsoft Clarity by deactivating cookies in your browser.

Google Analytics

Our website uses Google Analytics, a web analytics service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies to enable an analysis of your use of our website. The information generated by the cookie about your use of our website (including your IP address) is generally transmitted to a Google server in the USA and stored there.

Google uses this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide us with further services related to website use and internet use. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.

Anonymisation of the IP Address

We have activated IP anonymisation on this website. This means that your IP address is shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area before transmission. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

Purpose of Data Processing

The information collected with Google Analytics helps us to analyse the use of our website and to continuously improve our offerings. This data is used exclusively for analysis purposes and not to create user profiles.

Legal Basis for Data Processing

The data is processed on the basis of your consent pursuant to Art. 6(1)(a) GDPR. You can withdraw your consent at any time by adjusting the cookie settings in your browser or by installing an appropriate opt-out plug-in.

How Can You Deactivate Data Collection?

You can prevent the storage of cookies by adjusting your browser software accordingly; however, please note that in this case you may not be able to use all functions of this website to their full extent.

5. Newsletter

Newsletter Data

If you would like to receive the newsletter offered on the website, we require an email address from you. Further data is not collected or is only collected on a voluntary basis. We use this data exclusively for sending the requested information about products, events and news. We use HubSpot for sending (see section "HubSpot"). Beyond this, we do not pass on this data to third parties.

The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent to the storage of the data, the email address and its use for sending the newsletter at any time, for example via the "unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the withdrawal.

The data you have provided to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe or once the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6(1)(f) GDPR.

Data stored by us for other purposes remains unaffected.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

6. Use of External Service Providers

Content Delivery Network (CDN)

We use a Content Delivery Network (CDN) to optimise the performance and availability of our website. The images and videos on our website are delivered via this network; the texts are generated on the server side and delivered via our hoster. For this purpose, the service provider that makes this network available processes your IP address and the information about when you visited our website. Videos on our careers page are only loaded when you play them. All further information on data processing by this service provider can be found in its privacy notice.

We base this processing on a legitimate interest (Art. 6(1)(f) GDPR). Our legitimate interest in using a Content Delivery Network is to be able to display our website as quickly, securely and reliably as possible.

Sanity

We use the Sanity service on our website. The provider of the service is Sanity AS, Trondheimsveien 2K, 0560 Oslo, Norway. Sanity also serves as our content management system (CMS) for managing the content of our website.

Sanity hosts its services on the Google Cloud Platform and uses further sub-processors, some of which are based in the USA. The use of the service may therefore result in a data transfer to a third country (USA). This transfer is based on the Standard Contractual Clauses of the EU Commission. We have concluded a data processing agreement (DPA) with Sanity.

Further information can be found in the provider's privacy notice at the following URL: https://www.sanity.io/legal/privacy.