Privacy Policy

In accordance with the provisions of the Regulation (EU) 679/2016, General Data Protection  Regulation (hereinafter, "GDPR") and the Organic Law 3/2018, of December 5, on Data Protection and Guarantee of Digital Rights (hereinafter, "LOPDGDD") through this Privacy Policy informs the user of Combinder Website or the investor (hereinafter, the "Data subject") of the conditions of processing of their personal data. 

1. IDENTIFICATION OF THE CONTROLLER

Owner: Combinder (a software development project represented by Kai Siefert, currently in preparation of company foundation; hereinafter "Data Controller");
Registered Office: Regus Westbahnhof, BahnhofCity Wien West, Europaplatz 2/1/2, Vienna, 1150, Austria 
E-mail: hello@combinder.io

2. DATA PROCESSING ACTIVITIES

As its business activity, Combinder connects distributed energy resources (DERs) and enables trading, optimization, and management of energy assets through its software and APIs. In this regard, Combinder processes personal data of the data subject as a data controller by contractual obligation, determining the purposes and means of the processing.

All personal data requested to the data subject are mandatory, not being possible to provide the service without the corresponding data processing by the Controller.With regard to Cookies, information on how they work is provided in the Cookies Policy.

ACTIVITY: SUBSCRIBE TO THE NEWSLETTERSOURCE: From the data subject through the forms available on the Combinder Website. 
LAWFULNESS OF PROCESSING: To take steps at the request of the data subject prior to entering the contract (Art. 6.1. b GDPR).PURPOSES: Fulfil the data subject’s request for registering for the first time as a Combinder user or subscribing to the newsletter.
DATA CATEGORIES: E-mail address RECIPIENTS: Sharing data with third parties is not foreseen.  
STORAGE PERIODS: The data must be kept until the purpose for which they were collected is achieved, unless the Data Controller is required to keep them by a legal obligation or to defend itself in the event of a claim. When the data subject has registered on the Website and has accepted the General Conditions of Use, he/she has become a customer. Therefore, since the contractual liability expires after 5 years, the data of the data subject may be kept for a period of 5 years from the end of the contractual relationship between them. If the data subject decides to exercise his right to delete this data, Combinder will block it, but will not delete it until the 5 years have elapsed.

3. INTERNATIONAL TRANSFERS OF PERSONAL DATA

As a rule, international data transfers will not be carried out; should this circumstance change, international data transfers will in any case be regulated by the appropriate legal instrument to provide sufficient guarantees when there is no adequacy decision on the country of destination.  

4. DATA SUBJECT OBLIGATIONS

The data subject guarantees that he/she is over eighteen (18) years old and that the information provided is true, accurate, complete and updated, being responsible for any damage or harm, direct or indirect, that could be caused as a consequence of the breach of such obligation. Combinder will not be held responsible for any incidence derived from the inaccuracy or falsehood of the information provided by the data subject, without predjudice to the right to rectification exercised by the Data subject. If the Data subject provides data of third parties, the Data subject guarantees that he/she has informed such third party of the aspects contained in this document and previously obtained his/her authorization or legally required consent to provide his/her data to Combinder for the purposes previously stated in this Privacy Policy.

5. DATA PROTECTION RIGHTS

In accordance with the provisions of the applicable data protection regulations, the Data Subject is informed that he/she may exercise his/her rights of access, rectification, deletion, opposition, data portability and limitation of processing directly to Combinder, by sending a message to the abovementioned email address. If, after exercising his/her rights to the Data Controller, he/she understands that his/her rights are being violated, the Data Subject may file a complaint to the Austrian Data Protection Agency. 

2024 © All rights reserved Combinder
Last update: June 2024