Villa Seilern Data Privacy Statement:
Director, Managing Director under commercial law
Villa Seilern Bad Ischl
Data Protection Officer contact information:
- Stock data (e.g., names, addresses)
- Contact data (e.g., e-mail, telephone numbers)
- Content data (e.g., text input, photographs, videos)
- Usage data (e.g., websites visited, interest in content, access times)
- Meta/communication data (e.g., device information, IP addresses
- Provision of the online offer, its functions and contents
- Responding to contact requests and communicating with users
- Safety measures
- Reach measurement/marketing
Visitors and users of the online offer. (In the following, we also refer to the data subjects collectively as “users”.)
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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 (e.g., cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations performed with or without the aid of automated procedures in connection with personal data. The term is very broad and covers virtually all handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical and organisational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement of that natural person.
“Controller” means the natural or legal person, public authority, agency or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
In accordance with Article 32 GDPR, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of processing, as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons.
Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling both physical access to the data as well as the access, input, disclosure, security, availability and separation thereof. Furthermore, we have set up procedures that ensure the exercise of data subject rights, erasure of data and response to data endangerment. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software and procedures in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 (1) lit. b GDPR, is necessary for the performance of the contract), if you have consented, if a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).
If we involve third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
You have the right to request a confirmation as to whether the data in question is being processed and to request information about this data as well as further information and copies of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question be erased immediately or, alternatively, to demand a restriction of the processing of the data in accordance with Art. 18 GDPR.
You have the right to request the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request their transmission to other controllers.
In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority.
Right to withdraw:
You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future.
Right to object:
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can be made in particular against the processing for direct marketing purposes.
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his/her visit to an online offer. Temporary cookies or “session cookies” or “transient cookies” are cookies that are erased after a user leaves an online offer and closes his/her browser. In such a cookie, the content of a shopping cart in an online shop or a login status, for example, can be stored. “Permanent” or “persistent” refers to cookies that remain stored even after closing the browser. For example, the login status can be saved when users visit the website again after several days.
Likewise, such a cookie can store the interests of users, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online offer (otherwise, if they are only their cookies, they are called “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be erased in the system settings of the browser.
The exclusion of cookies may lead to functional restrictions of this online offer.
The data processed by us will be erased or the processing of these data will be restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be erased as soon as the data are no longer required for their intended purpose and the erasure does not conflict with any statutory retention obligations. If the data is not erased because it is necessary for other and legally permissible purposes, the processing thereof will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
According to legal requirements in Austria, the storage takes place in particular for a period of seven years in accordance with Section 132 (1) Federal Fiscal Code [BAO] (accounting documents, receipts/invoices, accounts, receipts, business papers, statements of income and expenses, etc.), for a period of 22 years in connection with real estate and for a period of 10 years for documents in connection with electronically supplied services, telecommunications, radio and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is utilised.
In addition, we process contract data (e.g., subject matter of the contract, term, customer category) and payment data (e.g., bank details, payment history) of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We process the data of our customers in the context of the ordering processes in our online shop in order to enable them to select and order the selected products and services as well as the payment, delivery or execution thereof.
The processed data comprises stock data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners.
The processing takes place for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. We use session cookies for the storage of the shopping cart content and permanent cookies for the storage of the login status.
The processing is carried out on the basis of Art. 6 (1) lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as required is required for the establishment and fulfilment of the contract.
We disclose the data to third parties only in the context of delivery, payment or within the framework of legal permissions and obligations towards legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g., at the customer’s request upon delivery or payment).
Users can optionally create a user account in which they can view their orders in particular. As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be erased with regard to the user account, subject to retention thereof for commercial or tax reasons. Art. 6 (1) lit. c GDPR is required. Information in the customer account remains until its erasure with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to back up their data before the end of the contract in the event of termination.
As part of the registration and subsequent logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests and the interests of the users in misuse and other unauthorised use. As a basic principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) lit. c GDPR. Erasure takes place after expiry of statutory warranty and comparable obligations, the necessity of storing the data is checked every three years; in the case of the statutory archiving obligations, the erasure takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in accordance with Art. 6 (1) lit. b GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this way, the type, scope, purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data generally include stock and master data of the clients (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.) and payment data (e.g., bank details, payment history, etc.).
As part of our services, we may also use special categories of data in accordance with Art. 9 (1) GDPR, in particular, information on the health of the clients, possibly with reference to their sex life or sexual orientation, ethnic origin or religious or ideological beliefs.
For this purpose, if necessary, in accordance with Art. 6 (1) lit. a, Art. 7, Art. 9 (2) lit. a GDPR, we obtain express consent from the clients and process the special categories of data otherwise for health care purposes on the basis of Art. 9 (2) lit. h GDPR, Section 22 (1) no. 1 b Federal Data Protection Act [BDSG].
If required for the fulfilment of the contract or by law, we disclose or transmit the data of the clients in the context of communication with other specialists, third parties that are necessarily or typically involved for the fulfilment of the contract, such as billing offices or comparable service providers for example, provided that this is used for the provision of our services in accordance with Art. 6 (1) lit. b GDPR, legally required in accordance with Art. 6 (1) lit c GDPR, serves our interests or those of the clients for efficient and cost-effective healthcare as a legitimate interest in accordance with Art. 6 (1) lit. f GDPR, or is necessary in accordance with Art. 6 (1) lit. d GDPR.
To protect the vital interests of clients or another natural person or within the framework of consent in accordance with Art. 6 (1) lit. a. Art. 7 GDPR.
The erasure of the data takes place when the data is no longer required for the fulfilment of contractual or statutory duties of care, as well as for the handling of any warranty and comparable obligations, wherein the necessity of storing the data is reviewed every three years; in all other respects, the statutory retention obligations shall apply.
We process data in the context of administrative tasks as well as the organisation of our operations, financial accounting and the fulfilment of legal obligations, such as archiving for example. In doing so, we process the same data that we process in the context of the provision of our contractual services. The legal bases for processing include Art. 6 (1) lit. c GDPR, Art. 6 (1) lit. f GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lie in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that are used for the maintenance of our business activities, the performance of our tasks and the provision of our services. The erasure of the data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In doing so, we disclose or transmit data to the tax administration, to consultants, such as tax consultants or auditors as well as to other fee offices and payment service providers.
Furthermore, on the basis of our business interests, we store information about suppliers, organisers and other business partners, for example, for the purpose of later contact. As a basic principle, we store this mostly company-related data permanently.
When contacting us (e.g., via contact form, e-mail, telephone or social media), the user’s details are used to process the contact request and its processing in accordance with Art. 6 (1) lit. b (in the context of contractual/pre-contractual relationships), Art. 6 (1) lit. f (other requests) GDPR. The information provided by users may be stored in a customer relationship management system (“CRM system”) or a comparable application for the organisation of requests.
We erase the requests if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
With the following information, we clarify the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure, as well as your rights to object. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter referred to as “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are significantly involved in the consent of the users. In addition, our newsletters contain information about our products and accompanying information (e.g., safety instructions), offers, promotions and information about our company.
Registration data: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of personal address.
Double opt-in and logging: The registration for our newsletter takes place in a so-called double opt-in procedure. That means, following registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
The dispatch of the newsletter and the associated performance measurement are carried out on the basis of the consent of the recipients in accordance with Art. 6 (1) lit. a, Art. 7 GDPR in conjunction with Section 107 (2) of the Telecommunications Act [TKG] or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 (1) lit. f GDPR in conjunction with Section 107 (2) and 3 of the Telecommunications Act [TKG].
The logging of the registration procedure is based on our legitimate interests in accordance with Art. 6 (1) lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove consent.
Termination/withdrawal – You can cancel the receipt of our newsletter at any time, i.e., withdraw your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we erase them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Sendinblue is used as newsletter software. Your data will be transmitted to Sendinblue GmbH. Sendinblue is prohibited from selling your data and using it for purposes other than sending newsletters. Sendinblue is a certified German provider selected according to the requirements of the General Data Protection Regulation and the Federal Data Protection Act. Further information can be found here: de.sendinblue.com/informationen-newsletter-empfaenger/
The shipping service provider may use the data of the recipients in pseudonymous form, i.e., without assignment to a user, to optimise or improve its own services, for example, for the technical optimisation of sending and presenting the newsletter, or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to write to them itself or to pass on the data to third parties.
The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server or from the server of a shipping service provider, if we use one, when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval are initially collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on the retrieval locations (which can be determined with the aid of the IP address) or the access times.
Statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour, nor, provided we use one, that of the shipping service provider, to observe individual users.
In fact, the evaluations rather serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
A separate withdrawal of the performance measurement is unfortunately not possible; in this case the entire newsletter subscription must be terminated.
The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process stock data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in efficiently and securely providing this online offer in accordance with Art. 6 (1) lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of 7 days and then erased. Data whose further storage is necessary for evidentiary purposes are excluded from erasure until the respective incident has ultimately been clarified.
Google is certified under the Privacy Shield Agreement and thus offers the guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services associated with the use of this online offer and the use of the Internet. Pseudonymised user profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymisation. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of the users will be erased or anonymised after 38 months.
We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”) on the basis of our legitimate interests (i.e., interest in the analysis and optimisation and cost-effective operation of our online offer in accordance with Art. 6 (1) lit. f GDPR).
Google is certified under the Privacy Shield Agreement and thus offers the guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the online marketing procedure Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offer in a more targeted manner in order to present users only with ads that potentially correspond to their interests. If a user is shown, for example, ads for products that he/she has been interested in on other online offers, this is referred to as “re-marketing”.
For these purposes, when you visit our and other websites on which the Google advertising network is active, Google executes a code from Google directly and so-called (re-)marketing tags (invisible graphics or codes, also referred to as “web beacons”) are embedded on the website. With their aid, an individual cookie, i.e., a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). In this file, it is noted which websites the user visited, which content he/she is interested in, and which offers the user has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer.
Furthermore, we receive an individual “conversion cookie”. The information collected with the aid of the cookie is used by Google to compile conversion statistics for us. We only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information that personally identifies users.
The data of the users are processed pseudonymously within the framework of the Google advertising network. This means that Google does not store and process e.g., the name or e-mail address of the users, but processes the relevant data cookie-relatedly within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.
Within our online offer, due to our legitimate interests in the analysis, optimisation and cost-effective operation of our online offer and for these purposes, the so-called “Facebook pixel” of the social network Facebook is used. This is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are located in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield Agreement and thus offers the guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the aid of the Facebook pixel, Facebook is able to target visitors to our online offer for the presentation of advertisements (so-called “Facebook Ads”).
Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g., interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the aid of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear annoying. With the aid of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).
The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, you will find general information on the presentation of Facebook ads in Facebook’s data usage policy: https://www.facebook.com/policy. For specific information and details about the Facebook pixel and how it works, visit Facebook’s Help Center: https://www.facebook.com/business/help/651294705016616.
You can object to being tracked by the Facebook pixel and the use of your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions for the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e., they are applied to all devices such as desktop computers or mobile devices.
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the territory of the European Union. This can result in risks for the users, because, for example, the enforcement of the rights of the users could be made more difficult. With regard to US providers who are certified under the Privacy Shield, we would like to point out that they are thus committed to complying with the data protection standards of the EU.
Furthermore, the data of the users are usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behaviour and the inferable interests of the users. The usage profiles can in turn be used to place, for example, advertisements inside and outside the platforms that presumably correspond to the interests of the users.
For these purposes, cookies are usually stored on users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data can also be stored in usage profiles regardless of the devices used by the users (in particular, if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is carried out on the basis of our legitimate interests in effectively informing users and communicating with users in accordance with Art. 6 (1) lit. f GDPR. If the users are asked by the respective providers for consent to data processing (i.e., declare their consent, for example, by ticking a checkbox or confirming a button), the legal basis for the processing is Art. 6 (1) lit. a, Art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the information of the providers linked below.
Even in the case of requests for information and the assertion of user rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
On the basis of our legitimate interests (i.e., interest in the analysis and optimisation and cost-effective operation of our online offer in accordance with Art. 6 (1) lit. f GDPR), we use content or service offers from third-party providers within our online offer in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always requires that the third-party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore necessary for the presentation of this content. We endeavour to use only such content whose respective providers use the IP address only to deliver the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring websites, visit time and other information on the use of our online offer, as well as be combined with such information from other sources.
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually given as part of the settings of their mobile devices). The data may be processed in the USA. Data privacy statement: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
We integrate the timetable information “Scotty” of the provider ÖBB-Personenverkehr AG, Am Hauptbahnhof 2, 1100 Vienna, Austria. Data privacy statement: http://www.oebb.at/static/tarife/datenschutzerklaerung/index.html