Data protection

Introduction and overview

We have prepared this privacy policy (version 27.10.2022-112267465) to explain to you, in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller - and the processors commissioned by us (e.g. providers) - process, will process in the future and what lawful options you have. The terms used are to be understood as gender-neutral.

Data protection declarations usually sound very technical and use legal jargon. This privacy policy, on the other hand, is intended to describe the most important things to you as simply and transparently as possible. Where it is conducive to transparency, technical terms are explained in a reader-friendly way, links to further information are provided and graphics are used. We thus inform you in clear and simple language that we only process personal data as part of our business activities if there is a corresponding legal basis. This is certainly not possible by providing explanations that are as concise, unclear and legally technical as possible, as is often standard on the Internet when it comes to data protection. I hope you find the following explanations interesting and informative and perhaps there is one or two pieces of information that you did not yet know.

If you still have any questions, please contact the responsible body named below or in the legal notice, follow the links provided and view further information on third-party websites. Our contact details can of course also be found in the legal notice.

Area of application

This privacy policy applies to all personal data processed by us in the company and to all personal data processed by companies commissioned by us (processors). By personal data, we mean information within the meaning of Art. 4 No. 1 GDPR, such as a person's name, email address and postal address. The processing of personal data ensures that we can offer and bill our services and products, whether online or offline. The scope of this privacy policy includes

  • all online presences (websites, online stores) that we operate
  • Social media presence and e-mail communication
  • Mobile apps for smartphones and other devices

In short, the privacy policy applies to all areas in which personal data is processed in the company in a structured manner via the channels mentioned. If we enter into legal relationships with you outside of these channels, we will inform you separately if necessary.

Legal basis

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data. As far as EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course read this EU General Data Protection Regulation online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

  • Consent (Article 6(1)(a) GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of the data you entered in a contact form.
  • Contract (Article 6(1)(b) GDPR): In order to fulfill a contract or pre-contractual obligations with you, we process your data. For example, if we conclude a purchase contract with you, we need personal information in advance.
  • Legal obligation (Article 6(1)(c) GDPR): If we are subject to a legal obligation, we process your data. For example, we are legally obliged to keep invoices for accounting purposes. These usually contain personal data.
  • Legitimate interests (Article 6(1)(f) GDPR): In the case of legitimate interests that do not restrict your fundamental rights, we reserve the right to process personal data. For example, we need to process certain data in order to operate our website securely and efficiently. This processing is therefore a legitimate interest.

Other conditions such as recording in the public interest, the exercise of official authority and the protection of vital interests do not generally apply to us. If such a legal basis is relevant, it will be indicated at the appropriate point.

In addition to the EU regulation, national laws also apply:

  • In Austria, this is the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act), or DSG for short.
  • In Germany, the Federal Data Protection Act (BDSG) applies.

If other regional or national laws apply, we will inform you of this in the following sections.

Contact details of the person responsible

If you have any questions about data protection or the processing of personal data, you will find the contact details of the person or body responsible below:

DIGGERS GmbH
Murauerstr. 13, 8811 Scheifling, AUSTRIA
office@diggers.tech, +43 3582 21028

Storage duration

It is a general criterion for us that we only store personal data for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as the reason for the data processing no longer exists. In some cases, we are legally obliged to store certain data even after the original purpose has ceased to exist, for example for accounting purposes. If you wish your data to be deleted or revoke your consent to data processing, the data will be deleted as quickly as possible, provided there is no obligation to store it. We will inform you below about the specific duration of the respective data processing if we have further information on this.

Rights under the General Data Protection Regulation

In accordance with Articles 13, 14 GDPR, we inform you of the following rights to which you are entitled in order to ensure fair and transparent processing of data:

  • According to Article 15 GDPR, you have a right to information as to whether we process your data. If this is the case, you have the right to receive a copy of the data and the following information:
    • the purpose for which we carry out the processing;
    • the categories, i.e. the types of data that are processed;
    • who receives this data and, if the data is transferred to third countries, how security can be guaranteed;
    • how long the data will be stored;
    • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
    • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
    • the origin of the data if we have not collected it from you;
    • whether profiling is carried out, i.e. whether data is automatically analyzed in order to create a personal profile of you.
  • According to Article 16 GDPR, you have a right to rectification of data, which means that we must correct data if you find errors.
  • According to Article 17 GDPR, you have the right to erasure ("right to be forgotten"), which specifically means that you may request the erasure of your data.
  • According to Article 18 GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it any further.
  • According to Article 20 GDPR, you have the right to data portability, which means that we will provide you with your data in a commonly used format upon request.
  • According to Article 21 GDPR, you have the right to object, which will result in a change in the processing after enforcement.
    • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you can object to the processing. We will then check as quickly as possible whether we can legally comply with this objection.
    • If data is used for direct marketing purposes, you can object to this type of data processing at any time. We may then no longer use your data for direct marketing.
    • If data is used for profiling purposes, you can object to this type of data processing at any time. We may then no longer use your data for profiling.
  • According to Article 22 GDPR, you may have the right not to be subject to a decision based solely on automated processing (e.g. profiling).
  • According to Article 77 GDPR, you have the right to lodge a complaint. This means that you can lodge a complaint with the data protection authority at any time if you believe that the processing of personal data violates the GDPR.

If you believe that the processing of your data violates data protection law or that your data protection rights have been violated in any other way, you can lodge a complaint with the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:


Austrian Data Protection Authority

Dr. Andrea Jelinek
Barichgasse 40-42, 1030 Vienna
+43 1 521520,dsb@dsb.gv.at, www.dsb.gv.at

Communication

Communication summary
Data subjects: Anyone who communicates with us by phone, email or online form
Processed data: e.g. telephone number, name, email address, form data entered. You can find more details on this in the respective contact type used
Purpose: Processing communication with customers, business partners, etc.
Storage duration: Duration of the business case and the statutory provisions
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. b GDPR (contract), Art. 6 para. 1 lit. f GDPR (legitimate interests)

When you contact us and communicate by telephone, e-mail or online form, personal data may be processed. The data is processed for the handling and processing of your question and the associated business transaction. The data will be stored for as long as required by law.

Affected persons: All those who contact us via the communication channels provided by us are affected by the aforementioned processes.
Telephone: When you call us, the call data is stored pseudonymously on the respective end device and with the telecommunications provider used. In addition, data such as name and telephone number may subsequently be sent by e-mail and stored for the purpose of responding to inquiries. The data will be deleted as soon as the business case has been completed and legal requirements permit.
E-mail: If you communicate with us by email, data may be stored on the respective end device (computer, laptop, smartphone, etc.) and data may be stored on the email server. The data will be deleted as soon as the business transaction has been completed and legal requirements permit.
Online forms: If you communicate with us using an online form, data is stored on our web server and may be forwarded to one of our e-mail addresses. The data will be deleted as soon as the business transaction has been completed and legal requirements permit.

Legal basis

The processing of the data is based on the following legal bases:

  • Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to use it for purposes relating to the business transaction;
  • Art. 6 para. 1 lit. b GDPR (contract): It is necessary for the performance of a contract with you or a processor, such as the telephone provider, or we need to process the data for pre-contractual activities, such as the preparation of an offer;
  • Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to handle customer inquiries and business communication in a professional manner. This requires certain technical facilities such as e-mail programs, exchange servers and mobile network operators in order to be able to operate communication efficiently.

Data processing agreement (DPA)

In this section, we would like to explain what a data processing agreement is and why it is needed. Because the word "data processing agreement" is a bit of a mouthful, we will often only use the acronym DPA in this text. Like most companies, we do not work alone, but also use the services of other companies or individuals. By involving various companies or service providers, we may pass on personal data for processing. These partners then act as processors with whom we conclude a contract, the so-called data processing agreement (DPA). The most important thing for you to know is that the processing of your personal data takes place exclusively in accordance with our instructions and must be regulated by the DPA.

Who are processors?

As a company and website owner, we are responsible for all data that we process from you. In addition to controllers, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. More precisely and according to the GDPR definition: any natural or legal person, public authority, agency or other body which processes personal data on our behalf is considered a processor. Processors can therefore be service providers such as hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

To make the terminology easier to understand, here is an overview of the three roles in the GDPR Data subject (you as a customer or interested party) → Controller (we as a company and client) → Processor (service provider such as web host or cloud provider)

Content of an order processing contract

As mentioned above, we have concluded a DPA with our partners who act as processors. This states above all that the processor processes the data to be processed exclusively in accordance with the GDPR. The contract must be concluded in writing, although the electronic conclusion of the contract is also considered "written" in this context. The processing of personal data only takes place on the basis of the contract. The contract must contain the following:

  • Commitment to us as the responsible party
  • Obligations and rights of the controller
  • Categories of affected persons
  • Type of personal data
  • Nature and purpose of data processing
  • Purpose and duration of data processing
  • Place of data processing

Furthermore, the contract contains all obligations of the processor. The most important obligations are

  • Ensure data security measures
  • take possible technical and organizational measures to protect the rights of the data subject
  • to maintain a data processing directory
  • cooperate with the data protection supervisory authority at its request
  • carry out a risk analysis in relation to the personal data received
  • Sub-processors may only be commissioned with the written consent of the controller

You can find out what such an AVV looks like in concrete terms at https://www.wko.at/service/wirtschaftsrecht-gewerberecht/eu-dsgvo-mustervertrag-auftragsverarbeitung.html, for example. A sample contract is presented here.

Cookies

Cookies summary
Affected parties: Visitors to the website
Purpose: depending on the cookie. More details can be found below or from the manufacturer of the software that sets the cookie.
Processed data: Depending on the cookie used. You can find more details on this below or from the manufacturer of the software that sets the cookie.
Storage duration: depends on the cookie, can vary from hours to years
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit.f GDPR (legitimate interests)

What are cookies?
Our website uses HTTP cookies to store user-specific data. Below we explain what cookies are and why they are used so that you can better understand the following privacy policy. Whenever you surf the internet, you use a browser. Well-known browsers include Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text files in your browser. These files are called cookies. One thing cannot be denied: Cookies are really useful little helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are also other cookies for other areas of application. HTTP cookies are small files that are stored on your computer by our website. These cookie files are automatically stored in the cookie folder, the "brain" of your browser, so to speak. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified. Cookies store certain user data about you, such as language or personal page settings. When you visit our site again, your browser transmits the "user-related" information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are used to. In some browsers, each cookie has its own file; in others, such as Firefox, all cookies are stored in a single file. There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, third-party cookies are created by partner websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, Trojans or other "malware". Cookies also cannot access information on your PC.

What types of cookies are there?
The question of which cookies we use in particular depends on the services used and is clarified in the following sections of the privacy policy. At this point, we would like to briefly explain the different types of HTTP cookies.

A distinction can be made between 4 types of cookies:

  • Essential cookies
    These cookies are necessary to ensure basic website functions. For example, these cookies are needed when a user places a product in the shopping cart, then continues surfing on other pages and only goes to the checkout later. These cookies ensure that the shopping cart is not deleted even if the user closes their browser window.
  • Purposeful cookies
    These cookies collect information about user behavior and whether the user receives any error messages. These cookies are also used to measure the loading time and the behavior of the website with different browsers.
  • Targeted cookies
    These cookies ensure better user-friendliness. For example, entered locations, font sizes or form data are saved.
  • Advertising cookies
    These cookies are also called targeting cookies. They are used to deliver customized advertising to the user. This can be very practical, but also very annoying. When you visit a website for the first time, you are usually asked which of these types of cookie you would like to allow. And of course this decision is also saved in a cookie.

If you would like to know more about cookies and are not afraid of technical documentation, we recommend https://datatracker.ietf.org/doc/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called "HTTP State Management Mechanism".

Purpose of processing via cookies:
The purpose ultimately depends on the cookie in question. You can find more details on this below or from the manufacturer of the software that sets the cookie.

What data is processed?
Cookies are little helpers for many different tasks. Unfortunately, it is not possible to generalize which data is stored in cookies, but we will inform you about the processed or stored data in the following privacy policy.

Storage duration of cookies
The storage period depends on the cookie in question and is specified below. Some cookies are deleted after less than an hour, others can remain stored on a computer for several years.

You can also influence the storage period yourself. You can delete all cookies manually at any time via your browser (see also "Right to object" below). Furthermore, cookies that are based on consent will be deleted at the latest after you withdraw your consent, whereby the legality of the storage until then remains unaffected.

Right to object - how can I delete cookies?

You decide how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of deleting, deactivating or only partially allowing cookies. For example, you can block third-party cookies but allow all other cookies. If you want to find out which cookies have been stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:

  • Chrome: Delete, activate and manage cookies in Chrome
  • Safari: Managing cookies and website data with Safari
  • Firefox: Delete cookies to remove data that websites have stored on your computer
  • Internet Explorer: Deleting and managing cookies
  • Microsoft Edge: Deleting and managing cookies

If you generally do not want to have cookies, you can set up your browser so that it always informs you when a cookie is to be set. You can then decide for each individual cookie whether or not to allow it. The procedure differs depending on the browser. It is best to search for the instructions in Google using the search term "delete cookies Chrome" or "deactivate cookies Chrome" in the case of a Chrome browser.

Legal basis

The so-called "Cookie Guidelines" have been in place since 2009. These state that the storage of cookies requires your consent (Article 6(1)(a) GDPR). However, there are still very different reactions to these directives within the EU countries. In Austria, however, this directive has been implemented in Section 96 (3) of the Telecommunications Act (TKG). In Germany, the cookie directives have not been implemented as national law. Instead, this directive was largely implemented in Section 15 (3) of the Telemedia Act (TMG). For strictly necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 para. 1 lit. f GDPR), which in most cases are of an economic nature. We want to provide visitors to the website with a pleasant user experience and certain cookies are often absolutely necessary for this. If cookies that are not absolutely necessary are used, this is only done with your consent. The legal basis in this respect is Art. 6 para. 1 lit. a GDPR. In the following sections, you will be informed in more detail about the use of cookies if the software used uses cookies.

Web design introduction

Web design privacy policy summary
Data subjects: Visitors to the website
Purpose: Improvement of the user experience
Processed data: Which data is processed depends heavily on the services used. In most cases, this includes the IP address, technical data, language settings, browser version, screen resolution and browser name. You can find more details on this in the respective web design tools used.
Storage duration: depending on the tools used
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)

What is web design?

We use various tools on our website that serve our web design. Web design is not, as is often assumed, just about making our website look pretty, but also about functionality and performance. But of course the right look of a website is also one of the major goals of professional web design. Web design is a branch of media design and deals with the visual as well as the structural and functional design of a website. The aim of web design is to improve your experience on our website. In web design jargon, this is referred to as user experience (UX) and usability. User experience refers to all impressions and experiences that website visitors have on a website. Usability is a sub-item of user experience. This is about the user-friendliness of a website. The main focus here is on ensuring that content, subpages or products are clearly structured and that you can find what you are looking for quickly and easily. In order to offer you the best possible experience on our website, we also use third-party web design tools. In this privacy policy, the category "web design" therefore includes all services that improve the design of our website. These can be, for example, fonts, various plugins or other integrated web design functions.

Why do we use web design tools?

How you absorb information on a website depends very much on the structure, functionality and visual perception of the website. This is why good and professional web design has become increasingly important for us. We are constantly working on improving our website and also see this as an extended service for you as a website visitor. Furthermore, a beautiful and functioning website also has economic advantages for us. After all, you will only visit us and make use of our services if you feel completely at ease.

What data is stored by web design tools?

When you visit our website, web design elements may be integrated into our pages that can also process data. Exactly what data is involved naturally depends heavily on the tools used. Below you can see exactly which tools we use for our website. For more detailed information about data processing, we recommend that you also read the respective privacy policies of the tools used. In most cases, this will tell you what data is processed, whether cookies are used and how long the data is stored. Fonts such as Google Fonts also automatically transmit information such as language settings, IP address, browser version, browser screen resolution and browser name to the Google servers.

Duration of data processing

How long data is processed is very individual and depends on the web design elements used. If cookies are used, for example, the storage period can be as short as one minute or as long as a few years. Please find out more about this. We recommend that you read our general text section on cookies as well as the data protection declarations of the tools used. There you can usually find out exactly which cookies are used and what information is stored in them. Google font files, for example, are stored for one year. This is to improve the loading time of a website. In principle, data is only stored for as long as is necessary to provide the service. Data can also be stored for longer if required by law.

Right of objection

You also have the right and the option to withdraw your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. You can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser. Under web design elements (mostly fonts), however, there is also data that cannot be deleted quite so easily. This is the case when data is automatically collected directly when a page is accessed and transmitted to a third-party provider (such as Google). In this case, please contact the support of the relevant provider. In the case of Google, you can contact support at https://support.google.com/?hl=de.

Legal basis

If you have consented to the use of web design tools, the legal basis for the corresponding data processing is this consent. According to Art. 6 para. 1 lit. a GDPR (consent), this consent constitutes the legal basis for the processing of personal data, as may occur when it is collected by web design tools. We also have a legitimate interest in improving the web design on our website. After all, only then can we provide you with an attractive and professional website. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use web design tools if you have given your consent. We would like to emphasize this again here in any case.

Information on special web design tools - if available - can be found in the following sections.


Google Fonts Local Privacy Policy

We use Google Fonts from Google Inc. on our website. Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for the European region. We have integrated the Google fonts locally, i.e. on our web server - not on Google's servers. This means that there is no connection to Google servers and therefore no data transfer or storage.

What are Google Fonts?

Google Fonts used to also be called Google Web Fonts. This is an interactive directory with over 800 fonts that Google provides free of charge. With Google Fonts, you could use fonts without uploading them to your own server. However, in order to prevent any transfer of information to Google servers in this respect, we have downloaded the fonts to our server. In this way, we act in compliance with data protection regulations and do not send any data to Google Fonts.

Explanation of terms used

We always endeavor to write our privacy policy as clearly and comprehensibly as possible. However, this is not always easy, especially when it comes to technical and legal topics. It often makes sense to use legal terms (such as personal data) or certain technical terms (such as cookies, IP address). However, we do not want to use these without explanation. Below you will find an alphabetical list of important terms used, which we may not have sufficiently addressed in the previous privacy policy. If these terms have been taken from the GDPR and are definitions, we will also quote the GDPR texts here and add our own explanations if necessary.

Processor

Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term "processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; Explanation: As a company and website owner, we are responsible for all data that we process from you. In addition to the controller, there may also be so-called processors. This includes any company or person that processes personal data on our behalf. In addition to service providers such as tax consultants, processors can therefore also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Consent

Definition according to Article 4 of the GDPR
For the purposes of this Regulation, "consent" of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her; Explanation: In the case of websites, such consent is usually given via a cookie consent tool. You are probably familiar with this. Whenever you visit a website for the first time, you are usually asked via a banner whether you agree or consent to data processing. In most cases, you can also make individual settings and decide for yourself which data processing you allow and which you do not. If you do not give your consent, your personal data may not be processed. In principle, consent can of course also be given in writing, i.e. not via a tool.

Personal data

Definition according to Article 4 of the GDPR
For the purposes of this Regulation, "personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; Explanation: Personal data is therefore all data that can identify you as a person. This is usually data such as

  • Name
  • Address
  • E-mail address
  • Postal address
  • Phone number
  • Date of birth
  • Identification numbers such as social security number, tax identification number, identity card number or matriculation number
  • Bank data such as account number, credit information, account balances and much more.

According to the European Court of Justice (ECJ), your IP address is also considered personal data. IT experts can use your IP address to determine at least the approximate location of your device and, subsequently, you as the owner of the connection. Therefore, the storage of an IP address also requires a legal basis within the meaning of the GDPR. There are also so-called "special categories" of personal data, which are also particularly worthy of protection. These include

  • racial and ethnic origin
  • political opinions
  • religious or ideological convictions
  • trade union membership
  • genetic data such as data taken from blood or saliva samples
  • biometric data (i.e. information on psychological, physical or behavioral characteristics that can identify a person).
  • Health data
  • Data on sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR
For the purposes of this Regulation, "profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements; Explanation: Profiling involves the collection of various information about a person in order to find out more about that person. In the web sector, profiling is often used for advertising purposes or for credit checks. For example, web and advertising analysis programs collect data about your behavior and interests on a website. This results in a special user profile that can be used to target advertising to a specific target group.

Person responsible

Definition according to Article 4 of the GDPR
For the purposes of this Regulation, the term "controller" means 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law; Explanation: In our case, we are responsible for the processing of your personal data and are therefore the "controller". If we pass on collected data to other service providers for processing, these are "processors". An "order processing contract (AVV)" must be signed for this.

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