I. Name and address of the responsible personThe responsible person within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is:
Grünwald Equity Management GmbHSüdliche Münchner Str. 10
D-82031 Grünwald
Tel.:
+49 - 89 / 500 808 6- 0Fax.:
+49 - 89 / 500 808 6-160
www.gruenwaldequity.de
II. General information on data processing
Our privacy policy is intended to be simple and understandable for everyone. In this privacy policy, the official terms of the General Data ProtectionRegulation (DSGVO) are generally used. The official definitions are explained in Art. 4 DSGVO.
III. definitions
Our privacy policy is intended to be simple and understandable for everyone. In this privacy policy, the official terms of the General Data ProtectionRegulation (DSGVO) are generally used. The official definitions are explained in Art. 4 DSGVO.
IV. WebhostingThis website is hosted by an external service provider (DGTLS GmbH). This website is hosted in Munich, Germany. Personal data collected on this website is stored on the hoster's servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, website accesses and other data generated via a website. We have concluded an order processing contract with the provider in accordance with the requirements of Art. 28 DSGVO, in which we oblige the provider to protect our customers' data and not to pass it on to third parties.
V. Server-log filesWhen you access our website, it is technically necessary for data to be transmitted to our web server via your internet browser. The following data is recorded during an ongoing connection for communication between your internet browser and our web server:
- Date and time of the request
- Name of the requested file
- Page from which the file was requested
- Access status
- Web browser and operating system used
- (Complete) IP address of the requesting computer
- Transmitted data volume
We collect the listed data to ensure a smooth connection setup of the website and to enable a comfortable use of our website by the users. In addition, the log file is used to evaluate system security and stability as well as for administrative purposes. The legal basis for the temporary storage of the data or the log files is Art. 6 para. 1lit. f DSGVO. For reasons of technical security, in particular to defend against attempted attacks on our web server, we store this data for a short period of time. It is not possible for us to draw conclusions about individual persons on the basis of this data. After 7 days at the latest, the data is anonymised by shortening the IP address at domain level, so that it is no longer possible to establish a link to the individual user.
VI. Cookies
Our website uses so-called "cookies". Cookies are small text files that are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your terminal device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser. Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or language settings). Other cookies are used to evaluate user behaviour or to display advertising. Technically necessary cookies are stored on the basis of Art. 6para. 1 lit. f DSGVO. We have a legitimate interest in storing cookies for the technically error-free and optimised provision of our services. Other cookies are only stored with your consent on the basis of Art. 6 para. 1 lit. a DSGVO.The consent can be revoked at any time for the future. The legal basis may also arise from Art. 6 (1) lit. b DSGVO if the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures which are carried out at the request of the data subject. Insofar as cookies are used for analysis purposes, we will inform you separately about this within the framework of this data protection declaration and obtain your consent.
You can set your browser so that you
• Will be informed about the setting of the cookies,
• Allow cookies only in individual cases,
• exclude the acceptance of cookies for certain cases or in general,
• activate the automatic deletion of cookies when closing the browser.
The cookie settings can be managed under the following links for the respective browsers:
• Google Chrome
• Mozilla Firefox
• Edge (Microsoft)
• Safari
• Opera
You can also manage cookies of many companies and functions used for advertising individually. To do this, use the corresponding user tools, available at https://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/your-ad-choices.
Most browsers also offer a so-called"do-not-track" function. When this function is activated, the respective browser tells advertising networks, websites and applications that you do not want to be "tracked" for the purpose of behavioural advertising and the like. Information and instructions on how to edit this function can be obtained from the links below, depending on your browser provider:
• Google Chrome
• Mozilla Firefox
• Edge (Microsoft)
• Safari
• Opera
In addition, you can prevent the loading of so-called scripts by default. "NoScript" allows JavaScripts, Java and other plug-ins to be executed only on trusted domains of your choice.Information and instructions on how to edit this function can be obtained from the provider of your browser (e.g. for Mozilla Firefox at: https://addons.mozilla.org/de/firefox/addon/noscript/). Please note that if you deactivate cookies, the functionality of our website may be limited.
VII. General information on data processing
1. scope of the processing of personal data
As a matter of principle, we process personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services. The processing of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by legal regulations.
2. Legal basis for the processing of personal dataInsofar as we obtain the consent of the data subject for processing operations of personal data,Article 6 (1) lit. a of the EU General Data Protection Regulation (DSGVO)serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) c DSGVO serves as the legal basis. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.
3. Data deletion and storage periodThe personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies.Storage may take place beyond this if this has been provided for by theEuropean or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for the continued storage of the data for the conclusion or fulfilment of a contract.
VIII. Webanalysis by other providersYour personal data will not be transferred to third parties unless
- we have explicitly indicated this in the description of the respective data processing.
- if you have given your express consent in accordance with Art. 6 Para. 1 Sentence 1 lit. a DSGVO,
- the disclosure in accordance with Art. 6 Para. 1Sentence 1 lit. f DSGVO is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
- in the event that a legal obligation exists for the disclosure in accordance with Art. 6 para. 1 p. 1 lit. c DSGVO and
- if this is necessary for the processing of contractual relationships with you according to Art. 6 para. 1 p. 1 lit. bDSGVO.
In addition, we use external service providers for the processing of our services, which we have carefully selected, commissioned in writing and with whom we have concluded order processing agreements in accordance with Art. 28 DSGVO, if necessary.They are bound by our instructions and are regularly monitored by us. These are service providers for web hosting, sending e-mails and maintenance and care of our IT systems, etc. The service providers will not pass this data on to third parties.
Data processor Google Analytics Our website uses Google Analytics, an internet analysis service provided by Google Ireland Limited, Gordon House, BarrowStreet, Dublin 4, Ireland ("Google"). Google Analytics uses so-called"cookies".
Google will use thisinformation on behalf of the operator of this website for the purpose ofevaluating your use of the website, compiling reports on website activity andproviding other services relating to website activity. Google will also usethis information to provide the website operator with other services related tothe use of the website and the internet. The IP address sent by your browser aspart of Google Analytics will not be combined with any other data held byGoogle. The processing is carried out in accordance with Art. 6 para. 1 lit. aDSGVO on the basis of the consent you have given.
We only use Google Analytics with IP anonymisation activated. This means that your IP address is only processed by Google in a shortened form.
We have concluded an order processing contract with the service provider in which we oblige them to protect our customers' data and not to pass it on to third parties. As there is a transfer of personal data to the USA, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46 (2) lit. c DSGVO. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the USA.
The Google Analytics terms of use and information on data protection can be accessed via the following links:http://www.google.com/analytics/terms/de.htmlhttps://www.google.de/intl/de/policies/
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Deletion of user and event level data linked to cookies, user identifiers (e.g. user ID) and advertising IDs (e.g.DoubleClick cookies, Android advertising ID, IDFA [Apple identifier for advertisers]) takes place no later than 14 months after their collection.
You can prevent cookies from being saved by adjusting the settings of your browser software accordingly. However, we would like to point out that in this case you may not be able to use all functions of this website without restrictions. You can also prevent Google from collecting the data generated by the cookie and from analysing your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=de.
Google-Maps
Our homepage uses the online map service provider Google Maps via an interface. This enables us to show you interactive maps directly on the website and allows you to use the map function conveniently. The provider of the map service is Google IrelandLimited, Gordon House, Barrow Street, Dublin 4, Ireland. To use the functionalities of Google Maps, it is necessary to store your IP address. The legal basis for the processing of your personal data is your consent granted for this purpose in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO.By using the service, personal data is transferred to the USA. The legal basis for the transfer of your personal data to the USA is your consent pursuant to Art. 49 (1) sentence 1 lit. a DSGVO.
As there is a transfer of personal data to the USA, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46(2) lit. c DSGVO. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the USA. For further information on the handling of user data, please refer to Google's privacy policy:
Google: https://www.google.de/intl/de/policies/privacy/
Opt-out: https://www.google.com/settings/ads/
Web Fonts from Adobe Typekit
This site uses so-called web fonts provided byAdobe Typekit for the uniform display of fonts. Adobe Typekit is a service ofAdobe Systems Software Ireland Ltd. When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly. For this purpose, the browser you use must connect to Adobe's servers in the USA. This enables Adobe Typekit to know that our website has been accessed via your IP address.
As there is a transfer of personal data to the USA, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46 (2) lit. c DSGVO. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the USA.
Adobe Typekit Web Fonts are used in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO.
For more information on Adobe Typekit Web Fonts, please visit https://typekit.com/ and read the Adobe Typekit privacy policy: https://www.adobe.com/de/privacy/policies/typekit.html
Translation service Weglot
This website uses the translation service Weglot(https://weglot.com), registered at 138 rue Pierre Joigneaux, 92270 Bois-Colombes, France. Weglot is registered in the Trade Register of Nanterre, company register no. 818 164 964. Weglot anonymously prepares website content in other languages via an application interface. The service works dynamically with its translation machines and also with translation agencies. Personal data such as names and address fields are excluded from transmission.
IX. Data security
We take appropriate technical and organisational measures in accordance with Article 32 of the DSGVO, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk. This website uses SSL encryption for security reasons and to protect the transmission of confidential content.
X. Duration of storage of personal data
The duration of the storage of personal data is determined by the relevant statutory retention periods (e.g. from commercial law and tax law). After expiry of the respective period, the corresponding data is routinely deleted. If data is required to fulfil or initiate a contract or if we have a legitimate interest in continuing to store it, the data is deleted when it is no longer required for these purposes or you have exercised your right of revocation or objection.
XI. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the DSGVO and you have the following rights vis-à-vis the controller:
1. right to information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If there is such processing, you may request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the envisaged duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to obtain the rectification or erasure of personal data concerning you, a right to obtain the restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the DSGVO and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject. You have the right to request information on whether personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant toArticle 46 of the DSGVO in connection with the transfer.
2. right of rectification
You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller must make the rectification without undue delay.
3. right of restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of the processing but you need it for the establishment, exercise or defence of legal claims; or
(4) if you have objected to the processing pursuant to Article 21(1)DSGVO and it is not yet clear whether the controller's legitimate grounds override your grounds. Where the processing of personal data relating to you has been restricted, such data may only be processed - apart from being stored - with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a MemberState. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. right to erasure
a) Obligation to erase
You may request the controller to erase the personal data concerning you without undue delay and the controller is obliged to erase such data without undue delay if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a DSGVO and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Article 21(1) of the DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you have been collected in relation to information society services offered in accordance with Article 8(1) of the DSGVO.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the DSGVO, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, that personal data.
c) Exceptions
The right to erasure does not apply insofar as the processing is necessary to.
(1) for the exercise of the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise ofofficial authority vested in the controller;
(3) for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the DSGVO;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1)of the DSGVO, insofar as the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
(5) for the assertion, exercise or defence of legal claims.
5. right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right against the controller to be informed about these recipients.
6. right to data portabilityYou have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that. (1) the processing is based on consent pursuant to Art. 6 para. 1 lit. aDSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para.1 lit. b DSGVO and (2) the processing is carried out with the aid of automated procedures. In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons. The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. right to objectYou have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f)DSGVO; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications. If you wish to exercise your right of withdrawal or objection, simply send an e-mailto ck@gruenwaldequity.de.
8. right to revoke the declaration of consent under data protection law You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. Automated decision-making in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision (1) is necessary for the conclusion or performance of a contract between you and the controller, (2) is permissible on the basis of legal provisions of the Union or the Member States to which the controller is subject and these legal provisions contain appropriate measures to safeguard your rights and freedoms as well as your legitimate interests; or (3) is made with your express consent. However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the DSGVO, unlessArticle 9(2)(a) or (g) of the DGSVO applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests. With regard to the cases referred to in (1) and(3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. right to complain to a supervisory authorityWithout prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the DSGVO. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 DSGVO.
XII. Legal obligationsThe provision of personal data for the decision on the conclusion of a contract, the fulfilment of a contract or for the implementation of pre-contractual measures is voluntary. However, we can only make the decision in the context of contractual measures if you provide suchpersonal data that is required for the conclusion of the contract, the performance of the contract or pre-contractual measures.
XIII. Reservation of right to make changesWe reserve the right to adapt or update this data protection declaration if necessary in compliance with the applicable data protection regulations. In this way, we can adapt it to the current legal requirements and take into account changes to our services, e.g. when introducing new services. The most current version applies to your visit.
Status of this data protection declaration: 08.07.2021
