Privacy Policy
We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Smarter Finance 24 GmbH. Use of the Smarter Finance 24 GmbH website is generally possible without providing any personal data. However, if a data subject wishes to use special services offered by our company via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to Daniel Bossenz. By means of this privacy policy, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, data subjects are informed by means of this privacy policy about the rights to which they are entitled.
As the controller responsible for processing, Daniel Bossenz has implemented numerous technical and organisational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, internet-based data transmissions may generally contain security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy of Daniel Bossenz is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would first like to explain the terminology used.
In this privacy policy, we use, among others, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for processing
Controller or controller responsible for processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k) Consent
Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.
2. Name and address of the controller responsible for processing
Controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in Member States of the European Union and other provisions of a data protection nature is:
Smarter Finance 24 GmbH
Mr Daniel Bossenz
Josef-Orlopp-Straße 46
10365 Berlin
Germany
Tel.: 0800 2 67 73 69
E-mail: daniel[at]smarter-finance[dot]de
Website: www.smarter-finance.de
3. Name and address of the data protection officer
The data protection officer of the controller responsible for processing is:
Mr Daniel Bossenz
Josef-Orlopp-Straße 46
10365 Berlin
Germany
Tel.: 0800 2 67 73 69
E-mail: d_bossenz@taures.de
Website: www.der-investmentberater-berlin.com
Any data subject may, at any time, contact our data protection officer directly with all questions and suggestions regarding data protection.
4. Cookies
The websites of Daniel Bossenz use cookies. Cookies are text files that are stored on a computer system via an internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can assign the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognised and identified using the unique cookie ID.
Through the use of cookies, Daniel Bossenz can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised for the benefit of the user. As already mentioned, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter access data each time the website is visited, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the items a customer has placed in the virtual shopping basket via a cookie.
The data subject may, at any time, prevent the setting of cookies by our website by means of an appropriate setting of the internet browser used and may thus permanently object to the setting of cookies. Furthermore, cookies already set may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
5. Collection of general data and information
The website of Daniel Bossenz collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.
When using this general data and information, Daniel Bossenz does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the contents of our website correctly, (2) optimise the contents of our website as well as advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, Daniel Bossenz analyses anonymously collected data and information statistically and also with the aim of increasing data protection and data security in our company in order to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.
6. Subscription to our newsletter
On the website of Daniel Bossenz, users are given the opportunity to subscribe to our company’s newsletter. Which personal data is transmitted to the controller when ordering the newsletter results from the input mask used for this purpose.
Daniel Bossenz informs customers and business partners regularly by means of a newsletter about offers of the company. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for newsletter dispatch. For legal reasons, a confirmation e-mail is sent to the e-mail address entered by a data subject for the first time for newsletter dispatch using the double opt-in procedure. This confirmation e-mail serves to verify whether the owner of the e-mail address as the data subject has authorised receipt of the newsletter.
When registering for the newsletter, we also store the IP address assigned by the internet service provider (ISP) to the computer system used by the data subject at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as legal protection for the controller.
The personal data collected during registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail, provided this is necessary for the operation of the newsletter service or a registration in this regard, as may be the case in the event of modifications to the newsletter offer or changes in the technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. Consent to the storage of personal data that the data subject has given us for newsletter dispatch may be revoked at any time. For the purpose of revoking consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter dispatch at any time directly on the website of the controller or to inform the controller of this in another way.
7. Newsletter tracking
The newsletters of Daniel Bossenz contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails that are sent in HTML format in order to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, Daniel Bossenz can recognise whether and when an e-mail was opened by a data subject and which links contained in the e-mail were accessed by the data subject.
Such personal data collected through the tracking pixels contained in the newsletters is stored and analysed by the controller in order to optimise newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the respective separate declaration of consent submitted via the double opt-in procedure. After revocation, this personal data will be deleted by the controller. Unsubscribing from receipt of the newsletter is automatically interpreted by Daniel Bossenz as a revocation.
8. Contact possibility via the website
The website of Daniel Bossenz contains information required by law that enables a quick electronic contact to our company as well as direct communication with us, which also includes a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data transmitted voluntarily by a data subject to the controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Comment function in the blog on the website
Daniel Bossenz offers users the possibility to leave individual comments on individual blog contributions on a blog located on the website of the controller. A blog is a portal, usually publicly accessible, maintained on a website, in which one or more persons, called bloggers or web bloggers, can post articles or write thoughts in so-called blog posts. Blog posts can usually be commented on by third parties.
If a data subject leaves a comment on the blog published on this website, the comments left by the data subject are also stored and published, together with information on the time of the comment entry and the user name (pseudonym) chosen by the data subject. In addition, the IP address assigned by the internet service provider (ISP) to the data subject is logged. This storage of the IP address takes place for security reasons and in the event that the data subject violates the rights of third parties or posts unlawful content through a submitted comment. The storage of this personal data is therefore in the controller’s own interest so that they may exculpate themselves in the event of an infringement. There is no transfer of this collected personal data to third parties unless such a transfer is required by law or serves the legal defence of the controller.
10. Subscription to comments in the blog on the website
The comments made in the blog of Daniel Bossenz can generally be subscribed to by third parties. In particular, there is the possibility that a commentator subscribes to the comments following their comment on a specific blog post.
If a data subject decides for the option to subscribe to comments, the controller sends an automatic confirmation e-mail in order to check in the double opt-in procedure whether the owner of the specified e-mail address has really chosen this option. The option to subscribe to comments can be terminated at any time.
11. Routine erasure and blocking of personal data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose, or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.
If the storage purpose ceases to apply or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions.
12. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact an employee of the controller.
b) Right of access
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain from the controller at any time free information about their personal data stored and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- the existence of the right to request rectification or erasure of personal data concerning them, or restriction of processing by the controller, or to object to such processing
- the existence of a right to lodge a complaint with a supervisory authority
- where the personal data is not collected from the data subject: any available information as to its source
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject
Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, they may, at any time, contact an employee of the controller.
c) Right to rectification
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, they may, at any time, contact an employee of the controller.
d) Right to erasure (right to be forgotten)
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:
- The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
- The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
- The personal data has been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data was collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
If one of the above reasons applies and a data subject wishes to arrange the erasure of personal data stored by Daniel Bossenz, they may, at any time, contact an employee of the controller. An employee of Daniel Bossenz shall promptly ensure that the erasure request is complied with immediately.
Where Daniel Bossenz has made the personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, Daniel Bossenz, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, that personal data, insofar as processing is not required. The employee of Daniel Bossenz will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
- The controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Daniel Bossenz, they may, at any time, contact an employee of the controller. The employee of Daniel Bossenz will arrange the restriction of the processing.
f) Right to data portability
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and the processing is carried out by automated means, insofar as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may, at any time, contact an employee of Daniel Bossenz.
g) Right to object
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them, which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
Daniel Bossenz shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.
If Daniel Bossenz processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Daniel Bossenz to the processing for direct marketing purposes, Daniel Bossenz will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by Daniel Bossenz for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact any employee of Daniel Bossenz or another employee. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject affected by the processing of personal data shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them, or similarly significantly affects them, insofar as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Daniel Bossenz shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.
If the data subject wishes to exercise rights concerning automated decision-making, they may, at any time, contact an employee of the controller.
i) Right to withdraw data protection consent
Each data subject affected by the processing of personal data shall have the right granted by the European legislator to withdraw consent to processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, they may, at any time, contact an employee of the controller.
13. Data protection in applications and the application process
The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by e-mail or via a web form on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents are automatically erased two months after notification of the rejection decision, provided that no other legitimate interests of the controller oppose the erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the German General Equal Treatment Act (AGG).
14. Data protection provisions on the application and use of AddThis
The controller has integrated components of AddThis on this website. AddThis is a so-called bookmarking provider. The service enables simplified bookmarking of websites via buttons. By moving the mouse over the AddThis component or by clicking on it, a list of bookmarking and sharing services is displayed. AddThis is used on more than 15 million websites, and according to the operating company, the buttons are displayed more than 20 billion times per year.
The operating company of AddThis is AddThis, Inc., 1595 Spring Hill Road, Suite 300, Vienna, VA 22182, USA.
By each call of one of the individual pages of this website, which is operated by the controller and on which an AddThis component has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective AddThis component to download data from the website www.addthis.com. As part of this technical procedure, AddThis obtains knowledge of the visit and of which specific individual page of this website was used by the information technology system used by the data subject. Furthermore, AddThis obtains knowledge of the IP address assigned by the internet service provider (ISP) to the computer system used by the data subject, the browser type, browser language, the website visited before our website, the date and time of the visit to our website. AddThis uses this data to create anonymised user profiles. The data and information transmitted to AddThis in this way enable AddThis itself, as well as companies affiliated with AddThis or its partner companies, to target visitors of the controller’s websites with personalised and interest-based advertising.
AddThis displays personalised and interest-based advertising on the basis of a cookie set by the company. This cookie analyses the individual surfing behaviour of the computer system used by the data subject. The cookie stores the visits to websites originating from the computer system.
The data subject may prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and may thus permanently object to the setting of cookies. Such an adjustment to the internet browser used would also prevent AddThis from setting a cookie on the information technology system of the data subject. In addition, cookies already set by AddThis may be deleted at any time via an internet browser or other software programs.
The data subject also has the option of permanently objecting to the processing of personal data by AddThis. For this purpose, the data subject must press the opt-out button under the link http://www.addthis.com/privacy/opt-out, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the system of the data subject are deleted after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, by setting the opt-out cookie, there is the possibility that the websites of the controller may no longer be fully usable by the data subject.
The applicable data protection provisions of AddThis can be retrieved at http://www.addthis.com/privacy/privacy-policy.
15. Data protection provisions on the application and use of Facebook
The controller has integrated components of Facebook on this website. Facebook is a social network.
A social network is an internet-based social meeting place, an online community that generally enables users to communicate with one another and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or company-related information. Facebook enables users of the social network, among other things, to create private profiles, upload photos and network via friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller for the processing of personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
By each call of one of the individual pages of this website operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be retrieved at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical procedure, Facebook obtains knowledge of which specific sub-page of our website is visited by the data subject.
If the data subject is logged in to Facebook at the same time, Facebook recognises with each call of our website by the data subject and for the entire duration of the respective stay on our website which specific sub-page of our website is visited by the data subject. This information is collected through the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject clicks one of the Facebook buttons integrated on our website, for example the “Like” button, or if the data subject leaves a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.
Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged in to Facebook at the time of the call to our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of this information to Facebook is not desired by the data subject, then they may prevent this by logging off from their Facebook account before calling up our website.
The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it explains what setting options Facebook offers to protect the privacy of the data subject. Furthermore, different applications are available that make it possible to suppress data transmission to Facebook. Such applications may be used by the data subject to suppress data transmission to Facebook.
16. Data protection provisions on the application and use of Google Analytics (with anonymisation function)
The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analysis service collects, among other things, data about the website from which a data subject came to a website (so-called referrers), which sub-pages of the website were accessed, or how often and for what duration a sub-page was viewed. Web analysis is predominantly used for the optimisation of a website and for the cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the internet connection of the data subject is shortened and anonymised by Google if access to our internet pages originates from a Member State of the European Union or from another contracting state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is the analysis of visitor flows on our website. Google uses the data and information collected, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our internet pages, and to provide other services connected with the use of our website.
Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. By each call of one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which serves Google, among other things, to trace the origin of visitors and clicks and subsequently enable commission statements.
By means of the cookie, personal information is stored, for example the access time, the location from which an access originated and the frequency of visits to our website by the data subject. With each visit to our internet pages, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected via the technical procedure on to third parties.
The data subject may prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and may thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics may be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to and preventing the collection of data generated by Google Analytics related to the use of this website as well as the processing of this data by Google. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is later deleted, formatted or newly installed, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person attributable to their sphere of control, reinstallation or renewed activation of the browser add-on is possible.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/ and under http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.
17. Data protection provisions on the application and use of Google+
The controller has integrated the Google+ button as a component on this website. Google+ is a social network. A social network is an internet-based social meeting place, an online community that generally enables users to communicate with one another and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or business-related information. Google+ enables users of the social network, among other things, to create private profiles, upload photos and network via friend requests.
The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
By each call of one of the individual pages of this website operated by the controller and on which a Google+ button has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google+ button to download a representation of the corresponding Google+ button from Google. As part of this technical procedure, Google obtains knowledge of which specific sub-page of our website is visited by the data subject. More detailed information on Google+ is available at https://developers.google.com/+/.
If the data subject is logged in to Google+ at the same time, Google recognises with each call of our website by the data subject and for the entire duration of the respective stay on our website which specific sub-page of our website is visited by the data subject. This information is collected through the Google+ button and assigned by Google to the respective Google+ account of the data subject.
If the data subject clicks one of the Google+ buttons integrated on our website and thereby submits a Google+1 recommendation, Google assigns this information to the personal Google+ user account of the data subject and stores this personal data. Google stores the Google+1 recommendation of the data subject and makes it publicly available in accordance with the conditions accepted by the data subject in this regard. A Google+1 recommendation given by the data subject on this website is subsequently stored and processed together with other personal data, such as the name of the Google+1 account used by the data subject and the photo stored therein, in other Google services, for example the search engine results of the Google search engine, the Google account of the data subject or in other places, for example on websites or in connection with advertisements. Furthermore, Google is able to link the visit to this website with other personal data stored by Google. Google also records this personal information with the purpose of improving or optimising the various Google services.
Google receives information via the Google+ button that the data subject has visited our website whenever the data subject is logged in to Google+ at the time of the call to our website; this occurs regardless of whether the data subject clicks the Google+ button or not.
If the data subject does not wish personal data to be transmitted to Google, they may prevent such transmission by logging out of their Google+ account before calling up our website.
Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/. Further notes from Google on the Google+1 button may be retrieved at https://developers.google.com/+/web/buttons-policy.
18. Data protection provisions on the application and use of Google AdWords
The controller has integrated Google AdWords on this website. Google AdWords is a service for internet advertising that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords enables an advertiser to predefine certain keywords by means of which an ad is displayed in Google’s search engine results only when the user retrieves a search result relevant to the keyword using the search engine. In the Google advertising network, the ads are distributed to topic-relevant websites by means of an automatic algorithm and taking into account the predefined keywords.
The operating company of Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of Google AdWords is the promotion of our website by displaying relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party advertising on our website.
If a data subject reaches our website via a Google ad, a so-called conversion cookie is placed on the information technology system of the data subject by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to trace whether certain sub-pages, for example the shopping basket of an online shop system, were accessed on our website. Through the conversion cookie, both we and Google can understand whether a data subject who reached our website via an AdWords ad generated sales, i.e. completed or cancelled a purchase.
The data and information collected through the use of the conversion cookie are used by Google to create visitor statistics for our website. These visitor statistics are then used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimise our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
By means of the conversion cookie, personal information is stored, for example the websites visited by the data subject. Accordingly, with each visit to our websites, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected via the technical procedure on to third parties.
The data subject may prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and may thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie already set by Google AdWords may be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must call up the link www.google.de/settings/ads from each of the internet browsers they use and make the desired settings there.
Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/.
19. Data protection provisions on the application and use of Jetpack for WordPress
The controller has integrated Jetpack on this website. Jetpack is a WordPress plug-in that offers additional functions to the operator of a website built on WordPress. Among other things, Jetpack allows the website operator to obtain an overview of the visitors to the site. By displaying related posts and publications or the ability to share content on the site, it is also possible to increase visitor numbers. In addition, security features are integrated in Jetpack so that a website using Jetpack is better protected against brute force attacks. Jetpack also optimises and accelerates the loading of the images integrated on the website.
The operating company of the Jetpack plug-in for WordPress is Automattic Inc., 132 Hawthorne Street, San Francisco, CA 94107, USA. The operating company uses the tracking technology of Quantcast Inc., 201 Third Street, San Francisco, CA 94103, USA.
Jetpack places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By each call of one of the individual pages of this website operated by the controller and on which a Jetpack component has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Jetpack component to transmit data to Automattic for analysis purposes. As part of this technical procedure, Automattic obtains knowledge of data that is subsequently used to create an overview of website visits. The data obtained in this way serves to analyse the behaviour of the data subject who accessed the website of the controller and is evaluated with the aim of optimising the website. The data collected via the Jetpack component is not used to identify the data subject without prior explicit separate consent of the data subject. The data also comes to the knowledge of Quantcast. Quantcast uses the data for the same purposes as Automattic.
The data subject may prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and may thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Automattic/Quantcast from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Automattic may be deleted at any time via an internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to and preventing the collection of data generated by the Jetpack cookie related to a use of this website as well as the processing of this data by Automattic/Quantcast. For this purpose, the data subject must press the opt-out button under the link https://www.quantcast.com/opt-out/, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the system of the data subject are deleted after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, by setting the opt-out cookie, there is the possibility that the websites of the controller may no longer be fully usable by the data subject.
The applicable data protection provisions of Automattic are available at https://automattic.com/privacy/. The applicable data protection provisions of Quantcast are available at https://www.quantcast.com/privacy/.
20. Data protection provisions on the application and use of LinkedIn
The controller has integrated components of LinkedIn Corporation on this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and make new business contacts. More than 400 million registered people use LinkedIn in more than 200 countries. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. For privacy matters outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
Each time one of our internet pages that is equipped with a LinkedIn component (LinkedIn plug-in) is accessed, this component prompts the browser used by the data subject to download a corresponding display of the LinkedIn component. More information about the LinkedIn plug-ins may be accessed at https://developer.linkedin.com/plugins. As part of this technical procedure, LinkedIn obtains knowledge of which specific sub-page of our website is visited by the data subject.
If the data subject is logged in to LinkedIn at the same time, LinkedIn recognises with each call of our website by the data subject and for the entire duration of the respective stay on our website which specific sub-page of our website is visited by the data subject. This information is collected through the LinkedIn component and assigned by LinkedIn to the respective LinkedIn account of the data subject. If the data subject clicks a LinkedIn button integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores this personal data.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website whenever the data subject is logged in to LinkedIn at the time of the call to our website; this occurs regardless of whether the data subject clicks the LinkedIn component or not. If such a transfer of this information to LinkedIn is not desired by the data subject, they may prevent this by logging out of their LinkedIn account before calling up our website.
LinkedIn offers at https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads as well as to manage ad settings. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which may set cookies. Such cookies may be rejected under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy of LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. The LinkedIn cookie policy is available at https://www.linkedin.com/legal/cookie-policy.
21. Data protection provisions on the application and use of Twitter
The controller has integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and disseminate so-called tweets, i.e. short messages limited to 280 characters. These short messages are accessible to everyone, including persons not registered with Twitter. However, the tweets are also shown to the followers of the respective user. Followers are other Twitter users who follow the tweets of a user. Furthermore, Twitter enables addressing a broad audience via hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
By each call of one of the individual pages of this website operated by the controller and on which a Twitter component (Twitter button) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information on the Twitter buttons is available at https://about.twitter.com/de/resources/buttons. As part of this technical procedure, Twitter obtains knowledge of which specific sub-page of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to disseminate the content of this website, to make this website known in the digital world and to increase our visitor numbers.
If the data subject is logged in to Twitter at the same time, Twitter recognises with each call of our website by the data subject and for the entire duration of the respective stay on our website which specific sub-page of our website is visited by the data subject. This information is collected through the Twitter component and assigned by Twitter to the respective Twitter account of the data subject. If the data subject clicks one of the Twitter buttons integrated on our website, the data and information transmitted thereby are assigned to the personal Twitter user account of the data subject and stored and processed by Twitter.
Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged in to Twitter at the time of the call to our website; this occurs regardless of whether the data subject clicks the Twitter component or not. If such a transfer of this information to Twitter is not desired by the data subject, then they may prevent this by logging out of their Twitter account before calling up our website.
The applicable privacy policy of Twitter is available at https://twitter.com/privacy?lang=de.
22. Data protection provisions on the application and use of Xing
The controller has integrated components of Xing on this website. Xing is an internet-based social network that enables users to connect with existing business contacts and establish new business contacts. Individual users can create a personal profile on Xing. Companies may, for example, create company profiles or publish job offers on Xing.
The operating company of Xing is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
By each call of one of the individual pages of this website operated by the controller and on which a Xing component (Xing plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Xing component to download a representation of the corresponding Xing component from Xing. Further information about the Xing plug-ins may be accessed at https://dev.xing.com/plugins. As part of this technical procedure, Xing obtains knowledge of which specific sub-page of our website is visited by the data subject.
If the data subject is logged in to Xing at the same time, Xing recognises with each call of our website by the data subject and for the entire duration of the respective stay on our website which specific sub-page of our website is visited by the data subject. This information is collected through the Xing component and assigned by Xing to the respective Xing account of the data subject. If the data subject clicks one of the Xing buttons integrated on our website, for example the “Share” button, Xing assigns this information to the personal Xing user account of the data subject and stores this personal data.
Xing receives information via the Xing component that the data subject has visited our website whenever the data subject is logged in to Xing at the time of the call to our website; this occurs regardless of whether the data subject clicks the Xing component or not. If such a transfer of this information to Xing is not desired by the data subject, then they may prevent this by logging out of their Xing account before calling up our website.
The privacy policy published by Xing, which is available at https://www.xing.com/privacy, provides information about the collection, processing and use of personal data by Xing. Furthermore, Xing has published data protection notices for the XING share button at https://www.xing.com/app/share?op=data_protection.
23. Data protection provisions on the application and use of YouTube
The controller has integrated components of YouTube on this website. YouTube is an internet video portal that allows video publishers to upload video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all kinds of videos, which is why complete film and television programmes, as well as music videos, trailers, or videos made by users themselves, can be accessed via the internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
By each call of one of the individual pages of this website operated by the controller and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information about YouTube may be obtained at https://www.youtube.com/yt/about/de/. As part of this technical procedure, YouTube and Google obtain knowledge of which specific sub-page of our website is visited by the data subject.
If the data subject is logged in to YouTube at the same time, YouTube recognises, when calling up a sub-page containing a YouTube video, which specific sub-page of our website is visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google receive information via the YouTube component that the data subject has visited our website whenever the data subject is logged in to YouTube at the time of the call to our website; this occurs regardless of whether the data subject clicks a YouTube video or not. If such a transfer of this information to YouTube and Google is not desired by the data subject, this may be prevented by logging out of the YouTube account before calling up our website.
The privacy provisions published by YouTube, which are available at https://www.google.de/intl/de/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
23a. Data protection provisions on the application and use of smava
The loan comparison, as well as the banners and text links provided by smava that we use on our website, are an offer of smava GmbH (smava GmbH, Kopernikusstr. 35, 10243 Berlin). If you provide personal data when using the comparison calculator or making a non-binding request via our website, this data is collected by smava. Smava processes your data in accordance with European data protection provisions. Detailed information on data protection and your rights regarding the processing of your data can be found at any time in smava’s privacy policy: https://www.smava.de/Downloads/smava_Datenschutzerklaerung_062015.pdf
24. Legal basis for the processing
Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the supply of goods or to provide any other service or consideration, then the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in cases of enquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, then the processing is based on Art. 6(1)(c) GDPR. In rare cases, processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our business and their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal bases if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted to us because they have been specifically mentioned by the European legislator. In this respect, the legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (recital 47 sentence 2 GDPR).
25. Legitimate interests in the processing pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities in favour of the well-being of all our employees and shareholders.
26. Period for which the personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely erased, provided that it is no longer required for contract performance or contract initiation.
27. Statutory or contractual provisions governing the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will clarify to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.
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