Data Protection

Contact us

1. Introductory information

1.1 General information
The websites  https://investify.de, https://investify.lu  and https://investify.com are operated by investify S.A., 46, Grand Rue, 6630 Wasserbillig, Luxembourg, registered with the Luxembourg Register Court (RCS Luxembourg) under register number B 200777 (hereinafter: investify). The data collecting body (controller) is:

Investify S.A.
46, Grand Rue
6630 Wasserbillig
Luxembourg 
Email: service@investify.com

As changes in legislation or in our business processes may require an adaptation of this privacy statement, we kindly ask you to read this privacy statement on a regular basis.
For details of the data protection information referred to in Article 13 General Data Protection Regulation (hereinafter: GDPR) please click here (see Chapter 3. Privacy). 

1.2 External Data Protection Officer
The Data Protection Officer for investify can be reached at the following address: 

Herr Rechtsanwalt Dr. Karsten Kinast, LL.M. 
KINAST Rechtsanwaltsgesellschaft mbH 
Hohenzollernring 54, 50672 Köln (Cologne)
mail@kinast.eu 

1.3 Principles of data processing
Personal data means any information that relates to an identified or identifiable natural person. This includes information such as your name, age, address, telephone number, date of birth, email address, IP address or user behaviour. Information that we cannot (or only with a disproportionate effort) use to establish a connection to your person, e.g. due to anonymisation of the information, does not constitute personal data. 
The processing of personal data (e.g. the collection, retrieval, use, storage or transmission) always requires a legal basis or your consent.
Processed personal data will be deleted as soon as the purpose of the processing has been achieved and there is no longer any legally prescribed obligation to keep records.
If we process your personal data in order to provide you with specific offers, we will inform you in the following about the specific procedures, the scope and the purpose of data processing, the legal basis for processing and the respective storage period.

2. Collection, processing and use of personal data through investify

investify offers its users services via its own internet portal. In essence, the services include individual asset management as well as in-depth information on investment issues. In order to use these services, you must be a registered user. The registration is done via this website.

2.1 Provision and use of the website
When you access and use our website, we collect personal data that your browser automatically transmits to our server. This information is temporarily stored in a so-called log file. When you use our website, we collect the following data, which is technically necessary for us to display our website and to ensure its stability and security:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Website from which the access takes place (referrer URL)
  • The browser used and, if applicable, the operating system of your computer, as well as the name of your access provider

Article 6 Para. 1 Point f GDPR serves as the legal basis for the data processing outlined above. Processing of the above-mentioned data is necessary for the provision of a website and thus serves to protect a legitimate interest of our company. As soon as the specified data are no longer necessary to display the website, they are deleted. The collection of the data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. There is therefore no possibility of objection on the part of the user. Further storage may be carried out in individual cases if this is required by law.

2.2 Registration (client portal)
Parts of the internet portal are reserved for registered users and/or asset management clients. An email address is required for the registration. In order to be able to make a professional assessment of the financial situation, investify collects and stores various personal data on the user's financial situation, risk tolerance and willingness to delegate, as well as on the user’s level of education, experience and knowledge of financial products and investments in general.

In order to conclude an asset management agreement as well as the account and custody agreement this entails, the following personal data will be collected by investify and in part by the appointed service provider IDnow (IDnow GmbH, Auenstr. 100, 80469 Munich, Germany), forwarded to Baader Bank (Baader Bank AG, Weihenstephaner Straße 4, 85716 Unterschleissheim, Germany) for the purpose of opening an account and custody account, and stored by investify for the purpose of processing the agreement (as an example: name, title, date and place of birth, nationality, marital status, email address, address, telephone number(s), details of tax liability). During the personal identification conversation (video chat), photos and/or video recordings of the identification document and of the client are taken and stored. In addition, a sound recording of the conversation is made and stored. The information available on the identification document is checked and stored, in particular the type of identification document, its ID number and date of issue, and the issuing authority. A reference account must be specified for the subsequent transfer of funds. Due to the requirements of the Money Laundering Act and other legal regulations, information on the origin of the funds as well as on the status as a politically exposed person will also to be requested.

As a registered user, investify will provide you with a personal copy of the basic information on securities from the Bank-Verlag (Bank-Verlag GmbH, Wendelinstraße 1, 50933 Köln). In order for this document to be personalised, we will transfer your full name to a server of the Bank-Verlag, following which you will receive a personalised PDF document. The Bank-Verlag does not store these personal data, but uses them exclusively for the one-time generation of the document.

These data are only passed on or transmitted to third parties if this is necessary for the purpose of processing the contract or if you have given your prior consent. We would like to point out that data transmission over the internet (e.g. when communicating by email or other digital services) may have security gaps and that data may be transmitted via network nodes in several countries. With the current state of technology, a complete protection of data against access by unauthorised parties is not possible. 
According to Art. 6 Para. 1 Point b GDPR, the processing of the personal data presented serves to fulfil the asset management contract or to carry out pre-contractual measures. Due to legal regulations, investify will store the personal data for 5 years after the end of the business relationship. As a user you have the possibility to cancel the registration at any time. You can have the data stored about you changed at any time. To do so, please send an email to:

Investify S.A.
46, Grand Rue
6630 Wasserbillig
Luxembourg
service@investify.com

However, if the processed data are necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, an early deletion of the data is possible only if this does not conflict with contractual or legal obligations.

2.3 Contact information 

2.3.1 Contact request
Our website offers you the possibility to contact us. The personal data that you provide within the scope of your contact request will be used only for the purpose of answering your inquiry or your message and for the technical administration resulting from it.

When you use the contact form, the following personal data will be processed:

  • Surname, first name, form of address
  • Country selection
  • Email address
  • Telephone number (optional)
  • Content of your message

The data are stored in HubSpot. HubSpot is a service of HubSpot Inc., 25 First Street, Cambridge, MA 02141, USA with a subsidiary in Ireland, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland. The indication of your email address enables us to allocate your inquiry and respond to you. When the contact form is used, your personal data are not transmitted to third parties.

Personal data may also be transmitted to countries outside the EU/EEA, in particular the US. According to the European Court of Justice, the US offers an insufficient level of data protection compared to EU standards. Owing to the lack of an adequacy decision and without appropriate guarantees, there is in particular the risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without a redress system. In order to be able to guarantee an adequate level of protection of your personal data in the event of a transmission of personal data to so-called third countries, we have concluded EU-US standard contractual clauses with HubSpot. In addition, we work closely with the provider in order to ensure that your personal data are protected, if necessary with additional measures.

For more information on HubSpot’s privacy policy, please visit:
https://legal.hubspot.com/de/privacy-policy

In accordance with Art. 6 Abs. 1 Point f GDPR, our legitimate interest of being able to respond to your inquiry justifies the processing of data described above for the purpose of establishing contact with us.

The personal data are deleted once the intended purpose –in particular after responding to your inquiry– has been achieved. In this regard, any storage of your personal data beyond this will take place only if required by law.

2.3.2 HubSpot live chat (GGF)
Furthermore, in order to improve the user experience on our website we use HubSpot’s live chat services “Messages” (round chat icon in the right lower corner of the screen) to send and receive messages on some of the subpages. If you agree and use this function, the following data are transmitted to HubSpot’s servers:

  • Content of all sent and received chat messages
  • Contextual information (e.g. page on which the chat was used)
  • Optional: User’s email address (if provided by the user via the chat function)

Personal data may also be transmitted to countries outside the EU/EEA, in particular the US. According to the European Court of Justice, the US offers an insufficient level of data protection compared to EU standards. Owing to the lack of an adequacy decision and without appropriate guarantees, there is in particular the risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without a redress system. In order to be able to guarantee an adequate level of protection of your personal data in the event of a transmission of personal data to so-called third countries, we have concluded EU-US standard contractual clauses with HubSpot. In addition, we work closely with the provider in order to ensure that your personal data are protected, if necessary with additional measures.

For more information on HubSpot’s privacy policy, please visit:
https://legal.hubspot.com/de/privacy-policy

The legal basis for using the HubSpot’s chat service is Art. 6 Para. 1 Point a) GDPR. The user explicitly gives consent before his/her data are stored.

The personal data are deleted once the intended purpose –in particular after responding to your inquiry– has been achieved. In this regard, any storage of your personal data beyond this will take place only if required by law.

2.4 Newsletter
On our website you have the possibility to subscribe to a free newsletter. Our newsletter is designed to inform you about us and our offers. In order to send you the newsletter regularly, we need the following information from you:

  • Email address

When you register for the newsletter, we save your IP address and the date of registration. This storage serves only as proof in the event that a third party misuses an email address and registers to receive the newsletter without the knowledge of the entitled person. 
Your data will not be passed on to third parties in connection with the newsletter dispatch. 

We use the so-called double opt-in procedure for sending out newsletters, i.e. we will only send you the newsletter if you first confirm your registration via a confirmation email sent to you for this purpose using the link contained in the email. This allows us to ensure that only you yourself, as the owner of the email address provided, can subscribe to the newsletter. Your confirmation must be sent promptly after receipt of the confirmation email, otherwise your newsletter registration will be automatically deleted from our database.  The processing of your email address for the purpose of sending the newsletter is based on your declaration of consent in accordance with Art. 6 Para. 1 Point a GDPR. Your email address will be stored for as long as you subscribe to the newsletter. If you unsubscribe from the newsletter, your email address will be deleted. Storage of your data beyond this period can take place in individual cases, if this is required by law.

2.5. Applicant management
If you wish to apply for a job with us via our website, we require certain personal data from you in order to process your application. These include your name, email address, address, telephone number, date of birth and the application documents which you can send to us. The provision of these data is voluntary; however, without this information we may not be able to consider your application. The data will not be transmitted to third parties. The collection of these data serves only the purpose of processing your application documents for the application process.

The legal basis for processing your personal data from your application documents is Art. 6 Para. 1 Point b GDPR in conjunction with § 26 Para. 1 Federal Data Protection Act (BDSG).

The legal basis for the assertion of legal claims and assistance in legal disputes is Art. 6 Abs. 1 Point c and f GDPR.

We will store your data for a period of 6 months after the end of the application process (acceptance or rejection). After that, your personal data will be deleted, unless further storage is stipulated by law.

3. Transfer of data 

We only share your personal data with third parties if:

  • You have explicitly given your consent to this in accordance with Art. 6 Para. 1 Clause 1 Point a GDPR
  • this is permitted by law and necessary in accordance with Art. 6 Para. 1 Clause 1 Point b GDPR for the performance of a contract to which you are party
  • there is a legal obligation for the transfer pursuant to Art. 6 Para. 1 Clause 1 Point c GDPR
  • the transfer is necessary for the purposes of the legitimate commercial interests of the company as well as for the establishment, exercise or defence of legal claims pursuant to Art. 6 Para. 1 Clause 1 Point  f GDPR and there is no reason to believe that you have an overriding interest to protect your data from transfer.

In certain circumstances we are required by law to transfer your personal data to third parties. This is the case, for example, if we suspect that a crime has been committed or our website is misused. In this case we are under obligation to share your data with the respective prosecuting authorities. Beyond that, your data will be stored exclusively in our database and on our own servers or our processors’ servers.

4. Cookies and external services

Data processing operations that take place within the scope of using cookies are described in detail below. For more information, please visit our cookie consent manager.

4.1 General information on the utilisation of cookies
We use cookies on our website. Cookies are small files that are sent by us to the browser of your terminal device when you visit our website and are stored there. Some functions of our website cannot be offered without the use of cookies for which there is a technical necessity. Other cookies, however, enable us to perform various analyses. For example, cookies are able to recognise the browser you are using when you visit our website again and transmit various information to us. With the help of cookies we can, among other things, make our internet offering more user-friendly and effective for you, for example, by tracking your use of our website and determining your preferred settings (e.g. country and language settings). If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your end device. They cannot execute programs or contain viruses.

Various types of cookies are used on our website, the type and function of which are explained in detail below.

Function 1:
Functional (technically necessary) cookies
These cookies are required for technical reasons; they allow you to visit our website and use the functions provided by us.
In addition, these cookies contribute to the safe and proper use of the website.

Function 2:
Analytical and optimisation cookies
These cookies help website operators understand how visitors interact with websites by collecting and reporting information anonymously.

Function 3:
Marketing cookies
Marketing (third-party) cookies enable operators to show you different offers that correspond to your interests. These types of cookies can track web activities of users over a longer period of time. They may recognise you on different end devices you use. 
Furthermore, certain cookies can create a connection to your social networks and share contents of our website within your networks.

The legal basis for processing cookies that are technically necessary is our legitimate interest to process personal data as set forth in Art. 6 Para. 1 Point f GDPR. For cookies that are not technically necessary or for so-called third-party cookies, we require your consent. If you have given your consent to the use of cookies following the display of a notice (“cookie banner”) on the website, the lawfulness of processing is additionally given in accordance with Art. 6 Para. 1 Point a GDPR. You can revoke your consent for the future at any time by deactivating the cookies in your browser settings.

As soon as the information that has been sent to us via the cookies is no longer required to fulfil the purposes outlined above, the information will be deleted, particularly if cookies are deactivated. Further storage may be carried out in individual cases if this is required by law.

You can administer your cookie settings using the setting options listed below or by modifying your browser’s configuration options.

Most browsers are preconfigured to accept cookies by default. However, you can change the configuration of your browser to accept only certain cookies or no cookies at all. However, please note that you may not be able to use all functions of our website if you deactivate cookies on our website by modifying your browser settings. You can also delete cookies that are already stored in your browser or view how long cookies are stored for via your browser settings. Furthermore, you can modify your browser settings to notify you before cookies are stored. Because the functionality of various browsers can differ, please use your browser’s respective help menu to check the configuration options.

Should you wish to have a comprehensive list of all third parties that have accessed your internet browser, we advise you to install plug-ins that have been specially developed for this.

For more information on the individual cookies used, please visit our cookie consent manager, which also allows you to administer your consents. 

4.2 Individual cookies (particularly tracking and analytic tools)
For a complete list of the cookies used, please refer to our cookie consent manager.

4.2.1 Google Analytics
Our website uses Google Analytics, a web analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountainview, CA 94043 USA (“Google”). Google Analytics uses cookies. 
The information generated by these cookies, for example about the time, place and frequency of your use of this website, is usually transferred to a Google server in the US and stored there. When using Google Analytics, it is not excluded that the cookies set by Google Analytics may also collect other personal data in addition to the IP address. We would like to point out that Google may transfer this information to third parties if this is legally required or if third parties process these data on behalf of Google. 

Google will use the information generated by cookies on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide further services to the website operator in connection with the use of the website and the internet. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other Google data according to Google's own information. 

You may generally refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this website. 

It cannot be ruled out that the cookies set by Google Analytics may collect further personal data in addition to the IP address. In order to prevent information on your use of the website from being collected by Google Analytics and transmitted to Google Analytics, you can download and install a plug-in for your browser under the following link:
http://tools.google.com/dlpage/gaoptout?hl=de. 

This plug-in prevents information about your visit to the website from being transmitted to Google Analytics. Any other analysis is not prevented by this plug-in. 
Please note that you cannot use the browser plug-in described above when visiting our website via the browser of a mobile device (smartphone or tablet). By clicking on this link, a so-called opt-out cookie is placed in your browser. This prevents information about your visit to the website from being transmitted to Google Analytics. Please note that the opt-out cookie is valid only for this browser and only for this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted. In order to continue to prevent Google Analytics from recording the cookie, you must click the link again. The use of the opt-out cookie is also possible as an alternative to the above plug-in when using the browser on your computer. 

In order to ensure the best possible protection of your personal data, Google Analytics on this website has been extended by the code "anonymizeIp". This code ensures that the last 8 bits of IP addresses are deleted and your IP address is thus recorded anonymously (this is referred to as IP masking). Your IP address will be shortened by Google in principle even before it is transferred within member states of the European Union or in other signatory states of the Agreement on the European Economic Area and thus made anonymous. Only in exceptional cases is the full IP address transferred to a Google server in the US and shortened there.

Within the scope of using Google Analytics, personal data may be transmitted to countries outside the EU/EEA, in particular the US. In order to be able to guarantee an adequate level of protection of your personal data in the event of a transmission of personal data to so-called third countries, we have concluded EU-US standard contractual clauses with Google. According to the European Court of Justice, the US offers an insufficient level of data protection compared to EU standards. Owing to the lack of an adequacy decision and without appropriate guarantees, there is in particular the risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without a redress system. In addition, we work closely with Google in order to ensure that your personal data are protected, if necessary with additional measures.

For more information on this, visit http://tools.google.com/dlpage/gaoptout  or https://policies.google.com/ (general information on Google Analytics and privacy).

The legal basis for processing, as outlined in detail above, is your explicit consent, as specified in Art. 6 Para. 1 Point a GDPR. You can revoke your consent for the future at any time by modifying the settings in the cookie consent manager or by deactivating the cookies in your browser settings. For details on the storage period, refer to our cookie consent manager.

4.2.2 Google Tag Manager
The investify website uses Google Tag Manager (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Tag Manager is a solution that allows marketers to manage website tags through one interface. The Google Tag Manager tool itself does not place cookies; it merely places tags and does not collect personal data. The tool triggers other tags, which in turn may collect data. However, Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will remain for all tracking tags implemented with Google Tag Manager.

Within the scope of using this service, personal data may be transmitted to countries outside the EU/EEA, in particular the US. In order to be able to guarantee an adequate level of protection of your personal data in the event of a transmission of personal data to so-called third countries, we have concluded EU-US standard contractual clauses with Google. According to the European Court of Justice, the US offers an insufficient level of data protection compared to EU standards. Owing to the lack of an adequacy decision and without appropriate guarantees, there is in particular the risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without a redress system. In addition, we work closely with Google in order to ensure that your personal data are protected, if necessary with additional measures.

The legal basis for processing, as outlined in detail above, is your explicit consent, as specified in Art. 6 Para. 1 Point a GDPR. You can revoke your consent for the future at any time by modifying the settings in the cookie consent manager or by deactivating the cookies in your browser settings. For details on the storage period, refer to our cookie consent manager.

4.2.4 financeAds
We use the technology “financeAds Advertising“. Finance Ads Advertising is an analysis service of financeAds GmbH & Co. KG, Karlstraße 9, 90403 Nuremberg. To optimise our internet presence, financeAds uses cookies. Within the framework of processing partner programs, financeAds also sets so-called tracking cookies to correctly record leads and sales on the customer's PC (user of the partner's website). These cookies do not contain any personal data and are used only to assign transactions to the partners of financeAds. 
The legal basis for using these cookies is our legitimate interest in the transfer, as provided for in Art. 6 Para. 1 Point f GDPR. For details on the storage period, refer to our cookie consent manager.

5. Social plug-in (YouTube videos)

On some of our websites we embed YouTube videos. The corresponding plug-ins are provided by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter “YouTube”).

In order to prevent data from being transferred to the service providers in the US without the knowledge of the user, we have implemented passive social media buttons or a solution known as Shariff on our website. This causes the corresponding social plug-ins to be integrated only as a graphic on the website. These graphics contain a link to the website of the respective plug-in provider. You will only be forwarded to the respective provider’s service if you click on one of the graphics. This solution ensures that personal data are not transferred automatically to the provider of the respective social plug-in when you visit our website. If you click on one of the social plug-in graphics, data may be transferred to the respective service provider and stored there. If you do not click on the graphics, there will be no transfer of data between you and the respective social plug-in provider.

For more information about the Shariff solution, please visit the following website: https://www.heise.de/ct/artikel/Shariff-SocialMedia-Buttons-mit-Datenschutz-2467514.html 
After clicking on a social plug-in, YouTube receives a notification that you visited the corresponding page of our online service. Please note that this does not require you to have a user account with the respective service or be logged into it already. Should you however already have a user account with the respective service provider and also already be logged into this account while visiting our website, the information collected by the social plug-in will be directly linked to your account. If you do not want the information to be linked to your profile with the service provider, you must log out of your user account before clicking on one of the social plug-ins.

Please note that investify has no influence on whether and to what extent the respective service providers collect personal data. We do not know the scope, purpose and storage periods of any data collection that may take place. However, we would like to point out that you can expect social plug-ins to at least use and record the IP address and device-related information. There is also the possibility that the respective service providers use cookies.

Within the scope of using this service, personal data may be transmitted to countries outside the EU/EEA, in particular the US. In order to be able to guarantee an adequate level of protection of your personal data in the event of a transmission of personal data to so-called third countries, we have concluded EU-US standard contractual clauses with YouTube. According to the European Court of Justice, the US offers an insufficient level of data protection compared to EU standards. Owing to the lack of an adequacy decision and without appropriate guarantees, there is in particular the risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without a redress system. In addition, we work closely with Google in order to ensure that your personal data are protected, if necessary with additional measures.
The legal basis for processing, as outlined in detail above, is your explicit consent, as specified in Art. 6 Para. 1 Point a GDPR. You can revoke your consent for the future at any time by deactivating the cookies in your browser settings.

For more information on the purpose and scope of the data collection and on the processing of data by YouTube, visit the service provider’s privacy statements. Here you will also find more information about your respective rights and configuration options to protect your privacy
(https://policies.google.com/privacy).

5. Hyperlinks

On our website there are so-called hyperlinks to websites of other providers. When activating these hyperlinks, you will be forwarded from our website directly to the website of the respective provider. You can recognise this by the change of the URL, among other things. We cannot assume any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with the data protection regulations. Please inform yourself about the handling of your personal data by these companies directly on these websites.

6. External service providers

investify uses service providers and partners for the provision of services and the processing of your data in relation to our services. Insofar as these are processors, the service providers process the information exclusively as per our instructions; they are under an obligation to comply with the applicable data protection provisions. All processors have been carefully selected and are only granted access to your data to the extent and for the time needed to provide the services or to the extent that you have given your consent to the processing and use of your data. They include banks, identification providers, content management systems, communication providers, hosts and IT service providers.

Service providers located in countries like the US or in countries outside the European Union or the European Economic Area are subject to data protection regulations that generally do not protect personal data to the same extent as in the member states of the European Union. If your information is processed in a country that does not offer a level of data protection that is equivalent to the high standard of the European Union, we will ensure by means of contractual arrangements or other recognised instruments that your personal data are adequately protected.

7. Basic storage period

Your personal data will be deleted as soon as the respective purpose for the processing has been fulfilled or subsequently ceases to apply.

To be able to fulfil contractual obligations, data collected from you can be stored for as long as the contract exists, as well as 6 or 10 years beyond this period depending on the scope of the contract, in order to comply with the legal retention periods and clarify any possible queries or claims after expiry of the contract.

If we believe that data are necessary to verify or defend claims made against us or to initiate criminal proceedings or submit claims against you, us or third parties, the data may be stored by us for as long as such proceedings may be instituted.

For customer service purposes, the data collected from you may be stored for 3 to 10 years after the data collection has taken place, unless you request the deletion of these data and there are no contractual or legal retention periods that conflict with your request for deletion.

Relevant obligations to provide proof and to keep records are set forth in the German Commercial Code and the German Fiscal Code.

In these cases, the legal basis for processing the data are the respective legal regulations in conjunction with Art. 6 Para. 1 Point c GDPR.

In the event that a contract is not concluded, we will delete your data after 3 years at the end of the statutory limitation period.

8. Rights of the data subject

According to the provisions set forth in the GDPR, you as the subject of processing of personal data have the following rights:

  • In accordance with Art. 15 GDPR, you have the right to demand access to your personal data processed by us. In particular, you have the right to demand information about the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom your data have been or will be disclosed, the envisaged period for which the personal data will be stored, the right to request rectification, erasure, restriction of processing or to object to processing, the right to lodge a complaint, the source of your data where they are not collected by us, the transfer of your data to third countries or to international organisations, and the existence of automated decision-making, including profiling and, where applicable, meaningful information on the details thereof.
  • In accordance with Art. 16 GDPR, you have the right to immediately obtain the rectification of inaccurate or the completion of your personal data stored by us.
  • In accordance with Art. 17 GDPR you have the right to demand the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims.
  • In accordance with Art. 18 GDPR you have the right to obtain restriction of processing of your personal data where the accuracy of the data is contested by you, the processing is unlawful, we no longer require the data and you oppose to their erasure as you require them for the establishment, exercise or defence of legal claims. You are still entitled to the right stipulated in Art. 18 GDPR if you have objected to the processing of your personal data in accordance with Art. 21 GDPR.
  • In accordance with Art. 20 GDPR you have the right to receive the personal data concerning you, which you have provided us with, in a structured, commonly used and machine-readable format, or you have the right to transmit these data to another controller.
  • In accordance with Art. 7 Para. 3 GDPR, you have the right to withdraw your consent at any time by informing us accordingly. As a result, we may no longer continue to process the data based on this consent in the future.
  • In accordance with Art. 77 GDPR you have the right to lodge a complaint with a supervisory authority. As a rule, you can apply to the supervisory authority of your usual place of residence, your place of work or our company headquarters for this purpose.

9. Right to object, Art. 21 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you under the conditions provided for in Art. 21 GDPR unless we have legitimate grounds for the processing under Art. 6 Para. 1 Point f GDPR. 

10. Data security and security measures

We undertake to protect your privacy and to treat your personal data confidentially. In order to avoid manipulation, loss or misuse of your data stored with us, we take extensive technical and organisational security measures which are checked and adapted to technological progress on a regular basis. This includes, among other things, the use of recognised encryption procedures (SSL or TLS). We would like to point out, however, that due to the structure of the internet it is possible that the rules of data protection and the above-mentioned security measures may not be observed by other persons or institutions that are not within our area of responsibility. In particular, data that are disclosed in unencrypted form (e.g. when sent by email) may be read by third parties. We have no technical influence on this. It is the responsibility of the user to protect the data provided by him/her against misuse by means of encryption or in any other way.

Version dated 25/01/2022