Partner Privacy Notice

Art. 13 GDPR information for Partners and their contact persons using the RingsX Partner Portal. This is an operational notice so partners can use the portal safely now. Independent legal review can refine wording later — it does not block portal use.

1. Controller

Tobias Huemer, trading as RingsX
Tachlau 2, 4655 Vorchdorf, Austria
VAT ID: ATU82803101
Email: info@ringsx.app

RingsX is the controller for personal data processed in connection with the Partner Portal, partnership administration, flyer logistics and partner payouts.

2. Who this notice is for

This notice applies to Partners (companies / entrepreneurs) and their natural-person contacts (e.g. account users, authorised signatories, billing contacts, warehouse contacts) — not to RingsX end-customer app users.

3. Categories of data we process

• Account data: login email, password (hashed by authentication provider), display name, partner role / seller ID
• Partnership acceptance data: name, role, acceptance timestamp, agreement version / acknowledgements
• Company / billing profile: legal name, address, country, entity type, contact person, billing email, language
• Tax-relevant data: VAT ID / tax numbers, VAT / small-business status declarations, tax residence
• Payout data: account holder, IBAN/BIC or equivalent local bank details, payout rail / currency
• Flyer logistics: shipping / warehouse addresses, contacts, quantities and related operational notes
• Portal usage needed to operate the service (authentication, security, support, audit logs)

4. Purposes and legal bases

• Perform the partnership (portal access, flyer setup, reporting, communications) — Art. 6(1)(b) GDPR (contract)
• Payouts and self-billing / tax documents — Art. 6(1)(b) and, where required, Art. 6(1)(c) (legal obligations under tax / accounting law)
• Security, abuse prevention, dispute handling — Art. 6(1)(f) (legitimate interests in securing B2B operations)

We do not use partner billing or bank details for marketing, and we do not publish your company data or share it with other partners.

5. Recipients / processors

• Google Firebase / Google Cloud (hosting, authentication, database, functions) as processors for RingsX
• Payment / banking channels used to execute partner payouts (e.g. SEPA / Wise), to the extent needed for payment
• Tax advisor / bookkeeping, where required for RingsX compliance
• Authorities, only where legally required

6. International transfers

Some infrastructure providers may process data outside the EEA. Where that occurs, RingsX relies on appropriate safeguards such as the European Commission’s Standard Contractual Clauses and provider compliance programmes.

7. Retention

• Portal account / operational data: for the duration of the partnership and a reasonable wind-down period
• Contract, billing, tax and payout records: for the statutory retention periods applicable in Austria (often up to 7 years or longer where mandatory)

8. End-customer data

In the standard partner programme, RingsX does not provide partners with personal end-customer or lead data. Partner reporting is designed to stay aggregated / limited as described in the Partner Agreement (§ 14).

9. Your rights

Where GDPR applies, you may request access, rectification, erasure, restriction, data portability and object to processing based on legitimate interests, subject to legal limits (especially retention for tax/contracts). Contact info@ringsx.app.

You may lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde): www.dsb.gv.at.

10. No mandatory marketing consent

Providing billing and tax data is required to receive partner payouts and compliant documents. It is processed under contract / legal obligation — not as a marketing opt-in.

Version 1.0 · Effective 2026-09-30 · RingsX Partner Privacy Notice