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Privacy policy and authorization for data usage

Data protection is a matter of trust and your trust is important to us. When processing your personal data, we strictly observe the statutory provisions. With the following data protection information, we would like to give you an overview of the processing of personal data held at Estably Asset Management Ltd. (hereinafter referred to as EST) and the resulting rights in accordance with the provisions of the new Basic Data Protection Regulation of the EU (GDPR) and the Data Protection Act (DSG). Which data is processed in detail and how it is used depends to a large extent on the services and products to be provided or agreed in each case. Due to banking secrecy, EST is obliged to protect your privacy and secrecy and for this reason takes a variety of technical and organisational data protection precautions for all data processing of personal data.

Within the framework of our business relationship, we are dependent on the processing of personal data which is necessary for the establishment and execution of the business relationship and the fulfilment of the associated legal or contractual obligations as well as for the provision of services or the execution of orders. Without this data, we will generally not be able to enter or maintain a business relationship, process an order or offer services and products.

Should you have any questions regarding individual data processing operations or wish to exercise your rights as described in point 5 below, please contact:

Responsible institution:

Estably Asset Management Ltd

Schaanerstrasse 29

9490 Vaduz

Liechtenstein

Phone: +423 220 29 70

 

Contact details of the data protection officer:

Estably Asset Management Ltd

Data protection officer

Schaanerstrasse 29

9490 Vaduz

Liechtenstein

Phone: +423 220 29 70

Which data are processed (data categories) and from which sources do they originate?

We collect and process personal data that we receive within the scope of our business relationship with our clients. Personal data may be processed at any stage of the business relationship and may vary from person to person.

In principle, we process personal data that you provide to us by means of submitted contracts, forms, your correspondence or other documents. If necessary for the provision of the service, we also process personal data which arises or is transmitted as a result of the use of products or services or which we have received from third parties (e.g. your custodian bank, the identification service provider), from public authorities (e.g. UN and EU sanctions lists). Finally, personal data may be processed from publicly accessible sources (e.g. trade and association registers, press, Internet).

In addition to customer data, we may also process personal data of other third parties involved in the business relationship, such as data of agents, representatives or beneficial owners of a business relationship. We would ask you to also inform any third parties about this data protection information. By personal data we mean the following categories of data:

Master data

  • personal details (e.g. name, date of birth, nationality)
  • Address and contact data (e.g. physical address, telephone number, e-mail address)
  • legitimation data (e.g. passport or identity card data) and
  • Authentication data (e.g. signature sample, log-in information)
  • data from publicly available sources (e.g. tax numbers)

 Further basic data

  • Information on services and products used (e.g. investment experience and profile, advice protocols, data on transactions executed)
  • Information on household structure and relationships (e.g. information on spouses or life partners and other family details, authorised signatories, legal representatives)
  • Information on financial characteristics and financial situation (e.g. portfolio and account number, creditworthiness data, origin of assets)
  • Information about professional and personal background (e.g. professional activity, hobbies, wishes, preferences)
  • Technical data and information on electronic traffic with EST (e.g. records of accesses or changes)
  • image and sound files (e.g. video or telephone recordings)

For what purposes and on what legal basis will your data be processed?

We process personal data in accordance with the provisions of the GDPR and the DSG for the following purposes or on the basis of the following legal bases:

To fulfil a contract or to carry out pre-contractual measures within the framework of the provision and brokerage of asset management, investment advice and other financial services which may be provided by EST.  The purposes of data processing depend primarily on the specific service or product (e.g. securities) and may include, but are not limited to, demand analyses, advice, asset management and the execution of transactions.

To fulfil legal obligations or in the public interest, in particular compliance with legal and supervisory requirements (e.g. compliance with the GDPR, the DSG, the Asset Management Act and Regulations), due diligence and anti-money laundering regulations, market abuse regulations, tax laws and agreements, control and reporting obligations, risk management). If you do not provide us with the necessary data, we will have to fulfil the relevant supervisory obligations and may be forced to terminate the business relationship.

In order to protect the legitimate interests of us or third parties for concretely defined purposes, in particular to determine creditworthiness, pursue claims, product development, marketing and advertising, business audits and risk management, reporting, statistics and planning, prevention and clarification of criminal offences, video surveillance to protect the right of domicile and avert danger, telephone recordings.

Based on your consent, which you have given us for the provision of asset management services or on the basis of orders such as the disclosure of data to service providers or contract partners of EST. You have the right to revoke your consent at any time. This also applies to the revocation of declarations of consent issued to EST before the GDPR came into force, i.e. before 25 May 2018.

The revocation of your consent is only effective for the future and does not affect the legality of the data processed until the revocation.

We reserve the right to process personal data collected for one of the above purposes for other purposes as well, if this is compatible with the original purpose or permitted or prescribed by law (e.g. reporting obligations).

Who gets access to the personal data and how long is it stored?

Access to your data can be both inside and outside EST. Within EST, only entities or employees may process your data if they need it to fulfil our contractual, legal and regulatory obligations and to safeguard legitimate interests. Other companies, service providers or vicarious agents may also receive personal data for these purposes in compliance with the relevant statutory provisions. Contract processors may be companies in the categories of asset management services, distribution agreements, IT services, logistics, printing services, consulting, sales and marketing. Furthermore, recipients of your data in this context may be other financial services institutions or comparable institutions to which we transfer personal data for the purpose of conducting the business relationship (e.g. custodian banks, brokers, stock exchanges, information centres).

If there is a legal or supervisory obligation, public bodies and institutions (e.g. supervisory authorities, financial authorities, etc.) may also receive your personal data. Data may only be transferred to countries outside the EU or the EEA (so-called third countries) if

  • this is necessary for the execution of pre-contractual measures or for the performance of a contract, for the provision of services or for the execution of orders (e.g. securities transactions)
  • you have given us your consent
  • this is necessary for important reasons of public interest (e.g. prevention of money laundering) or
  • this is required by law (e.g. transaction reporting obligations).

We process and store the personal data for the entire duration of the business relationship, unless there are shorter mandatory deletion obligations for certain data.

In addition, the duration of the storage depends on the necessity and purpose of the respective data processing. If the data are no longer necessary for the fulfilment of contractual or legal obligations or for the protection of our legitimate interests (achievement of purpose) or if a consent given is revoked, they are deleted regularly, unless further processing is necessary due to the contractual or legal retention periods and documentation obligations or for reasons of preservation of evidence during the duration of the applicable statute of limitations.

Is there an automated decision making process including profiling?

Some of our decisions are based on automated processing of personal data. There are business areas in which personal data is partly processed automatically. This is done with the aim of assessing certain personal aspects where we are required by law or regulation (e.g. prevention of money laundering), to analyse requirements for services and products, and as part of risk management.

A suitable investment strategy is determined on the basis of your investment objectives (including your willingness to take risks, your risk-bearing capacity and your knowledge and experience of securities). This determination is based exclusively on automated decision-making.

We partially process your data automatically with the aim of evaluating certain personal aspects (profiling). For example, we use profiling to provide you with targeted information and advice on products. The evaluation tools used for this purpose enable us to communicate and advertise according to your needs.

What data protection rights do you have?

With regard to the personal data concerning you, you have the following data protection rights in accordance with the GDPR (Art. 7, Art. 15 to 21)

  • Right of access: You may request information from EST as to whether and to what extent personal data relating to you will be processed (e.g. categories of personal data processed, purpose of processing, etc.).
  • Right to rectification, erasure and limitation of processing: You have the right to request rectification of any inaccurate or incomplete personal data concerning you. In addition, your personal data must be deleted if they are no longer necessary for the purposes for which they were collected or processed, if you have withdrawn your consent or if they are processed unlawfully. In addition, you have the right to request that the processing be restricted.
  • Right of withdrawal: You have the right to revoke your consent to the processing of your personal data for one or more specific purposes at any time if the processing is based on your express consent. This also applies to the revocation of declarations of consent issued before the GDPR came into force, i.e. before 25 May 2018. Please note that the revocation will only take effect in the future. Processing that took place before the revocation is not affected by this. The revocation also has no influence on data processing on another legal basis.
  • Right to data transfer: You have the right to receive the personal data concerning you that you have provided to the responsible person in a structured, common and machine-readable format and to have this data transferred to another responsible person.
  • Right of objection: You have the right to object informally to data processing in individual cases for reasons arising from your particular situation, provided that such processing is in the public interest or is carried out to safeguard the legitimate interests of EST or a third party. In addition, you have the right to object informally to the use of personal data for advertising purposes. If you object to the processing of your personal data for direct marketing purposes, we will no longer process your personal data for this purpose.
  • Right of complaint: You have the right to file a complaint with the competent Liechtenstein supervisory authority. You can also apply to another supervisory authority of an EU or EEA member state, for example, at your place of residence or work or at the place of the suspected infringement.

The contact details of the data protection office responsible in Liechtenstein are as follows:

Data Protection Office Liechtenstein

Städtle 38

FL-9490 Vaduz

Pricipality of Liechtenstein

Phone: + 423 236 60 90

E-mail: [email protected]

Requests for information or objections should preferably be made in writing to the data protection officer. He is also available to you as your contact for all other data protection matters.

Provision of the website and creation of log files

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as zanalysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

Hosting and Content Delivery Networks (CDN)

Hosting with Amazon Web Services

We host our CRM software on AWS. The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter: AWS).

If you register on our website by clicking the “Invest now” button or log in as a customer, your personal data will be processed on the servers of AWS as part of our CRM software. Only regions located in the EU or EEA have been explicitly named as storage locations in the contract with AWS. For its part, AWS uses sub-service providers for data processing, in particular Amazon.com Inc. based in Seattle/USA, which is why personal data may be transferred to the parent company of AWS in the USA. However, there is an adequate level of data protection for data transfers and processing by or to Amazon.com Inc. in the USA on the basis of a data protection agreement issued by the EU Commission in accordance with the review procedure under Art. 93(2) GDPR (so-called EU Standard Contractual Clauses). The Data Processing Addendum provides customers with the assurance that AWS will treat customers’ data according to the same high security and data protection standards that they would receive in the EU. All data is encrypted and stored according to the current state of the art.

A corresponding contract on order processing with AWS has been concluded between Estably and Amazon Web Services EMEA SARL. Amazon Web Services EMEA SARL is thus not authorized to process personal data of our customers beyond our instructions. You can find the necessary details about this at: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.

For more information, please refer to the AWS privacy policy: https://aws.amazon.com/privacy/?nc1=h_ls

The use of AWS is based on Art. 6 para. 1 lit. b GDPR.

Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

According to https://www.cloudflare.com/de-de/gdpr/introduction/, Cloudflare has no access to and no control over the data that customers transmit, route, switch, and cache over the Cloudflare Anycast network.

The invalidation of the Privacy Shield does not change the strong privacy protections Cloudflare has in place for the personal data we process on behalf of our customers. Cloudflare will continue to follow the privacy principles to which they committed when they were certified under the Privacy Shield. Cloudflare now relies on Standard Contractual Clauses (SCCs) as the legal mechanism for transferring personal data from the EEA to the US. Cloudflare requires a judicial process before providing customer data to a government entity outside of an emergency and notifies customers of any judicial process requesting customer or billing data before disclosing information. Cloudflare has publicly stated that it has never provided encryption keys to a government or used devices for law enforcement. Cloudflare pledges “would exhaust all legal remedies to protect our customers from what we believe to be illegal or unconstitutional requests.”

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6 Sect. 1 lit. f GDPR).

For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/.

General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Information on data transfer to the USA

Our website uses, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes.  We have no influence over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

In the event that data are processed on the basis of art. 6 sect. 1 lit. E or F GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to art. 21 sect. 1 GDPR).

If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to art. 21 sect. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in section “Information Required by Law” to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.

In some cases it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Cookie Consent with Borlabs Cookie

Our website uses the Borlabs cookie consent technology to obtain your consent to the storage of certain cookies in your browser and for their data privacy protection compliant documentation. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany (hereinafter referred to as Borlabs).

Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have entered. These data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for the use of cookies. The legal basis for the use of such cookies is Art. 6 Sect. 1 Sentence 1 lit. c GDPR.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

Registration on this website

You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise we shall reject the registration.

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.

We shall process the data entered during the registration process on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR).

The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

Social media

Facebook plug-ins (Like & Share button)

We have integrated plug-ins of the social network Facebook on this website. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

You will be able to recognize Facebook plug-ins by the Facebook logo or the “Like” button on this website. An overview of the Facebook plug-ins is available under the following link: https://developers.facebook.com/docs/plugins/.

Whenever you visit this website and its pages, the plug-in will establish a direct connection between your browser and the Facebook server. As a result, Facebook will receive the information that you have visited this website with your plug-in. However, if you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of this website and its pages with your Facebook profile. As a result, Facebook will be able to allocate the visit to this website and its pages to your Facebook user account. We have to point out, that we as the provider of the website do not have any knowledge of the transferred data and its use by Facebook. For more detailed information, please consult the Data Privacy Declaration of Facebook at: https://www.facebook.com/privacy/explanation.

If you do not want Facebook to be able to allocate your visit to this website and its pages to your Facebook user account, please log out of your Facebook account while you are on this website.

The use of the Facebook plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be revoked at any time.

Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g. cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

During your website visit, the following data is collected, among other things:

– The pages you visit, your “click path”

– Achievement of “website goals” (conversions, e.g. newsletter sign-ups, downloads, purchases)

– Your user behavior (for example, clicks, session time, bounce rates)

– Your approximate location (region)

– Your IP address (in shortened form)

– Technical information about your browser and the end devices you use (e.g., language setting, screen resolution)

– Your internet service provider

– The referrer URL (via which website/advertising medium you came to this website)

For more information on Google Analytics’ terms of use and Google’s privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/us/ and https://policies.google.com/

The legal basis for this data processing is your consent, Art.6 para.1 p.1 lit.a GDPR. You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. In order to analyze and improve the behavior of the offer, we also have a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Google Analytics is nevertheless only used after consent has been given.

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other

technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If the relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; the consent can be revoked at any time.

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g., concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at:

https://policies.google.com/privacy?hl=en

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics

This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the website visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender and interests of the website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.

Google Analytics E-Commerce-Tracking

This website uses the “E-Commerce Tracking” function of Google Analytics. With the assistance of E-Commerce Tracking, the website operator is in a position to analyze the purchasing patterns of website visitors with the aim of improving the operator’s online marketing campaigns. In this context, information, such as the orders placed, the average order values, shipping costs and the time from viewing the product to making the purchasing decision are tracked. These data may be consolidated by Google under a transaction ID, which is allocated to the respective user or the user’s device.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

Hotjar

This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (website: https://www.hotjar.com).

Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so-called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.

We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so-called conversion funnels).

The following data may be collected about your computer or browser:

  • IP address of your computer (collected and stored in an anonymous format)
  • Screen size
  • Browser info (which browser, which version, etc.)
  • Your location (but only the country)
  • Your preferred language setting
  • Visited web pages (sub-pages)
  • Date and time of access to one of our subpages (web pages)

However, Hotjar does not store any personal data for analysis (“we track behavior, not individuals”).

Hotjar servers are protected by firewalls and IP restrictions (access of approved IP addresses only). Hotjar has imposed on itself a 365-day data retention period. This means that all data collected by Hotjar that is older than one year is automatically deleted.

Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.

Hotjar uses technologies that make it possible to recognize the user for the purpose of analyzing the user patterns (e.g. cookies or the deployment of device fingerprinting).

The use of Hotjar requires your consent pursuant to Art. 6 para. 1 lit. a GDPR. In addition, there is a legitimate interest (pursuant to ARt. 6 para. 1 lit. f DSGVO) in analyzing the behavior of visitors and improving the offer. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

 

Deactivation of Hotjar

If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/opt-out.

Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.

For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g. location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

You have the option to participate in the conversion tracking of Google Ads. Insofar as you deactivate the Google conversion tracking cookie via the browser, conversion tracking will be blocked.

The use of Google Ads conversion tracking is based on consent pursuant to Art. 6 para. 1 lit. a GDPR. In addition, there is a legitimate interest (pursuant to ARt. 6 para. 1 lit. f GDPR) in optimizing online services and marketing measures.

Facebook Pixel

To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.

For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.

The use of Facebook Pixel is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.

You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under  https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.

If you do not have a Facebook account, you can deactivate any user based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

MailChimp

This website uses the services of MailChimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Among other things, MailChimp is a service that can be deployed to organize and analyze the sending of newsletters. Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your e-mail address), the information is stored on MailChimp servers in the United States.

With the assistance of the MailChimp tool, we can analyze the performance of our newsletter campaigns. If you open an e-mail that has been sent through the MailChimp tool, a file that has been integrated into the e-mail (a so-called web-beacon) connects to MailChimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.

If you do not want to permit an analysis by MailChimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message. Moreover, you can also unsubscribe from the newsletter right on the website.

The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR).  You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

For more details, please consult the Data Privacy Policies of MailChimp at: https://mailchimp.com/legal/terms/.

Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Web Fonts

To ensure that fonts used on this website are uniform, this website uses so-called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts.

To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. The use of Google Web Fonts is based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in a uniform presentation of the font on the operator’s website. If a respective declaration of consent has been obtained (e.g. consent to the archiving of cookies), the data will be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. Any such consent may be revoked at any time.

If your browser should not support Web Fonts, a standard font installed on your computer will be used.

For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Processing of data (customer and contract data)

We collect, process and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them.

The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.

Our social media appearances

Data processing through social networks

We maintain publicly available profiles in social networks. The individual social networks we use can be found below.

Social networks such as Facebook, Google+ etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:

If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.

Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.

Legal basis

Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 (1) (a) GDPR).

Responsibility and assertion of rights

If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g. Facebook).

Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.

Storage time

The data collected directly from us via the social media presence will be deleted from our systems as soon as the purpose for their storage lapses, you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular, retention periods – remain unaffected.

We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g. in their privacy policy, see below).

Individual social networks

Facebook

We have a profile on Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook’s statement the collected data will also be transferred to the USA and to other third-party countries.

You can customize your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.

Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

Twitter

We use the short message service Twitter. The provider is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

You can customize your Twitter privacy settings in your user account. Click on the following link and log in: https://twitter.com/personalization.

For details, see the Twitter Privacy Policy: https://twitter.com/privacy.

Instagram

We have a profile on Instagram. The provider is Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. For details on how they handle your personal information, see the Instagram Privacy Policy: https://help.instagram.com/519522125107875.

LinkedIn

We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

For details on how they handle your personal information, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.

Vimeo

We have a profile on Vimeo. The provider is Vimeo, Inc., 555 West 18th Street, New York 10011, USA. Details on how they handle your personal data can be found in the Vimeo privacy policy: https://vimeo.com/privacy.

YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.

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