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Privacy Policy

Data protection information in accordance with the General Data Protection Regulation (DS-GVO)

We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and these data protection notes. When you make use of our services, provide deliveries or services to us or communicate with us in any other way, we collect various personal data. Personal data is data with which you can be personally identified. This privacy notice explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Due to constant technical change, this data protection information is updated regularly. We therefore recommend that you regularly check this our information and notices on data processing for updates. The current version can be called up and printed out from this website at any time. We will explicitly inform you about basic updates via the website, by e-mail or by post if you are registered with us.

Insights

Disclaimer: This document has been translated using automated tools.

 

I. Responsibility for Data Processing

 

Walter Ludwig GmbH Wertpapierhandelsbank

An der Hauptwache 5

60313 Frankfurt am Main

Germany
Telefon: +49 69 13 38 52 - 35
E-Mail : datenschutz@van-grunsteyn.com
 

II. Data Processing in Connection with the Use of Our Services or Concerning Our Suppliers

 

If you are a customer, supplier, or are interested in entering into a contract with us, or if such a contract is being prepared, we process your personal data in the following ways:

1. Processing of Personal Data from the Following Sources

We process personal data that we receive in the context of business relationships with customers, service providers, or suppliers, or from intermediaries or investors.

Additionally, we process – as far as necessary – personal data that we have lawfully received from other companies, such as companies within the same corporate group, a capital management company, or from other third parties (for example, based on consent you have provided). If necessary and lawful, we also obtain personal data from individuals who are not in direct connection with us and who may belong to one of the following groups:

  • Legal representatives (authorized persons)

  • Beneficiaries of our customers

  • Ultimate beneficial owners of our customers

  • Shareholders

  • Representatives of legal entities

  • Employees of service providers or business partners

a. Data Processing When Using the Website www.van-grunsteyn.com

When you access our website, information is automatically sent to the server of our website by the browser used on your device. The following information is temporarily stored (until automatically deleted) in a log file:

  • IP address of the requesting device

  • Date and time of access

  • Name and URL of the accessed page or file

  • Website from which the access was made

  • Browser used, possibly the operating system of your device, and the name of your access provider

 

We use cookies when you visit our website. Cookies are small text files that can be stored on your device by website providers. The purpose of a cookie is to simplify your visit to the website. The cookies used do not aim to collect personal data about you. Cookies do not cause any damage to your devices, and they do not contain viruses, trojans, or other malicious software. Before being stored, each data set is anonymized by modifying the IP address. We use so-called "session cookies" to recognize that you have already visited individual pages of our website. These expire after leaving the website after a certain period. Furthermore, we also use temporary cookies to optimize user-friendliness, which are stored on your device for a specific period. If you visit our website again, it is automatically recognized that you have visited the site before. Additionally, we need cookies for analysis tools like "Google Analytics" (see below). If you do not wish to use cookies on your device, you must delete them yourself. You can configure your browser to inform you about the setting of cookies and to decide individually whether to accept them. If cookies are not accepted, the functionality of our website may be limited.

 

The website uses Google Analytics, a web analytics service provided by Google Inc. (https://www.google.de/intl/de/about/), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics creates pseudonymized user profiles and uses cookies that are stored on your device and enable an analysis of your use of the website. The information generated by the cookie about your usage is usually transmitted to and stored on a Google server in the USA. This includes the following information:

  • IP address of the requesting device

  • Date and time of access

  • Name and URL of the accessed page or file

  • Website from which the access was made

  • Browser used, possibly the operating system of your device

In the case of IP anonymization being activated on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You can prevent the storage of cookies by setting your browser accordingly. However, we would like to point out that in this case, you may not be able to fully use all functions of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

b. Data Processing in the Context of Information Provision

We provide you with information about the funds we manage and other information in various ways upon request, such as via email (newsletter) or by post. You can request this information through general communication channels or by using forms provided on the website. In this context, we may collect the following data in particular: name, email address, phone number, and address.

c. Data Processing in the Context of Supplier Relationships

We collect personal data from our suppliers in the course of the business relationship with them to ensure a smooth business relationship. In doing so, we collect the data of our contacts within the organization, such as names, phone numbers, and email addresses. Additionally, we collect bank details to be able to make payments to our suppliers.

 

2. Purpose and Legal Basis of Data Processing

 

We process the aforementioned personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

 

a. Data Processing for the Fulfillment of Contractual Obligations (Article 6(1)(b) GDPR)

 

The processing of personal data is carried out to provide our services in the context of fulfilling our contracts with our customers, to carry out pre-contractual measures at your request, or to provide other services. Regarding our supplier relationships, we process the personal data of individuals within our suppliers' organizations to be able to utilize their services. Additionally, we store financial data to facilitate the payment for services provided by our suppliers.

 

b. Data Processing Within the Scope of a Balancing of Interests (Article 6(1)(f) GDPR)

 

Where necessary, we process your data to protect our legitimate interests or those of third parties, for example:

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  • Reviewing and optimizing processes for direct communication, including segmentation

  • Advertising or market and opinion research, provided you have not objected to the use of your data

  • Assertion of legal claims and defense in legal disputes

  • Ensuring IT security and IT operations

  • Prevention of criminal offenses, especially fraud prevention

  • Video surveillance to protect property rights and to collect evidence in cases of robbery and fraud

  • Measures for building and facility security (e.g., access controls)

  • Other measures to ensure property rights

  • Measures for business management and the further development of services

 

With regard to the offered website www.van-grunsteyn.com:

  • Ensuring a smooth connection

  • Ensuring comfortable use

  • Evaluation of system security and stability

  • Other administrative purposes

 

Regarding cookies:

  • Optimizing user-friendliness

  • Statistical recordings

  • Optimizing our services for you

 

Regarding Google Analytics:

  • Tailored design of the website

  • Statistical analysis of website usage

 

Regarding Google DoubleClick Remarketing:

  • We use Google's remarketing technology. This technology allows users who have previously visited our website and shown interest in our offerings to be retargeted with relevant ads on Google partner network sites. Ads are displayed through the use of cookies. These text files allow user behavior on websites to be analyzed and then used for targeted product recommendations and interest-based advertising. No personal data of website visitors is stored. You can permanently deactivate the use of cookies by Google by following this link and downloading and installing the plugin provided there: https://www.google.com/settings/ads/plugin. DoubleClick cookies can also be deactivated by visiting the NAI (Network Advertising Initiative) deactivation page at https://optout.networkadvertising.org/?c=1. For more information on Google Remarketing and Google's privacy policy, you can visit: https://policies.google.com/privacy.

 

Regarding Google Conversion Tracking:

  • Furthermore, as part of the use of the Google AdWords service, we use conversion tracking. When you click on an ad placed by Google, a cookie for conversion tracking is set on your device. These cookies expire after 30 days, do not contain any personal data, and therefore do not serve to personally identify you. The information collected through the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. The users' data is processed pseudonymously within the framework of Google Marketing Services. This means that Google does not store or process the users' names or email addresses, but processes the relevant data in a cookie-based manner within pseudonymous user profiles. From Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected via Google Marketing Services about users is transmitted to and stored on Google's servers in the USA.

  • Among the Google Marketing Services we use is the online advertising program "Google AdWords." We specifically use the remarketing function within the Google AdWords service. In the case of Google AdWords, each AdWords customer receives a different conversion cookie. Therefore, cookies cannot be tracked across the websites of AdWords customers. The information collected through the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that can personally identify users.

  • We may include third-party advertisements based on the Google Marketing Service "DoubleClick." DoubleClick uses cookies that allow Google and its partner websites to serve ads based on users' visits to this website and other websites on the internet.

  • We may also use the "Google Tag Manager" to integrate and manage Google Analytics and marketing services on our website. Google Tag Manager is a solution that allows marketers to manage website tags via a single interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and only triggers other tags, which may in turn collect data. Google Tag Manager does not access this data. If a deactivation has been carried out at the domain or cookie level, it remains in effect for all tracking tags implemented with Google Tag Manager. We may ask for your permission to share some product data with other Google products to enable certain features, such as adding new conversion tracking tags for AdWords. Additionally, our developers may occasionally review usage information to optimize the product further. For more information, refer to the usage policy for this product at https://marketingplatform.google.com/intl/en/about/analytics/tag-manager/use-policy/.

  • For more information on Google's use of data for marketing purposes, you can visit the overview page: https://www.google.com/policies/technologies/ads, and Google's privacy policy can be found at https://www.google.com/policies/privacy. If you wish to object to interest-based advertising through Google Marketing Services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com.

  • Further information about Google and Google's privacy policy can be viewed at http://www.google.com/privacy/ads/. Additionally, you can disable interest-based Google ads on Google and on the internet (within the Google Display Network) in your browser by turning "Off" the option at https://adssettings.google.com or by opting out at http://www.aboutads.info/choices. Further information on your options regarding these settings and privacy at Google can be found at https://www.google.com/intl/en/policies/privacy/?fg=1.

 

c. Data Processing Based on Your Consent (Article 6(1)(a) GDPR)

If you have given us consent to process personal data for specific purposes (e.g., sharing data within the corporate group or using your data for specific advertising purposes), the legality of this processing is based on your consent. Data processing for the purpose of contacting us is based on your voluntarily provided consent, for example, if you use the newsletter registration on our website or hand us a business card. Consent given can be revoked at any time. Please note that the revocation only takes effect for the future. Processing that took place before the revocation is not affected. If we intend to use your personal data for purposes other than those mentioned above, we will inform you accordingly and, if necessary, obtain your consent.

d. Data Processing Based on Legal Obligations (Article 6(1)(c) GDPR) or in the Public Interest (Article 6(1)(e) GDPR)

We are subject to various legal obligations, meaning statutory requirements (such as tax laws) as well as regulatory provisions. The purpose of the processing includes, among other things, obligations for fraud and money laundering prevention, compliance with sanctions and embargo regulations, responding to official inquiries from a competent government authority or judicial body, fulfilling tax-related control and reporting obligations, as well as assessing and managing risks.

3. Obligation to Provide Data

If we maintain a business relationship, you must provide the personal data necessary for the initiation and execution of this business relationship and for fulfilling the associated contractual obligations, or the data we are legally required to collect. Without this data, we will generally have to refuse to enter into or execute the contract, or we may not be able to continue an existing contract and may need to terminate it. In particular, we are legally required under anti-money laundering regulations to identify customers before establishing a business relationship.

4. Who Receives Your Personal Data?

Within van Grunsteyn GmbH, only those departments that need your data to fulfill our contractual and legal obligations have access to it. Service providers and agents employed by us may also receive data for these purposes, provided they respect banking confidentiality and comply with our written data protection instructions. We may only share information about you if legal provisions require it, you have consented, or processors contracted by us guarantee compliance with the requirements of the GDPR or the BDSG. Under these conditions, recipients of personal data may include:

  • Public authorities and institutions (e.g., Deutsche Bundesbank, Federal Financial Supervisory Authority (BaFin), European supervisory authority, tax authorities, Federal Central Tax Office) in the presence of a legal or regulatory obligation.

  • Other credit and financial institutions, comparable institutions, and processors to whom we transfer personal data to carry out our business relationship with you. These companies are also legally or contractually obligated to handle personal data with the required care. In particular, we collaborate with IT service providers, financial service providers, and custodian banks.

  • Service providers who support us in the following specific activities: support/maintenance of IT/EDP applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data destruction, procurement, space management, real estate appraisals, credit processing services, collateral management, collections, customer management, letter shops, marketing, dispatching customer gifts, media technology, reporting, research, risk controlling, expense accounting, telephony, video identification, website management, securities services, share registers, fund management, auditing services, payment processing, independent representatives, intermediaries, brokers.

  • Members of certain regulated professions, such as lawyers, notaries, or auditors.

  • Additional data recipients may include those entities for which you have granted your consent to data transmission or those for whom you have released us according to agreement or consent.

 

III. How Are Your Personal Data Protected?

We take reasonable and appropriate measures to protect the information we store and process from misuse, loss, or unauthorized access. For this purpose, we have implemented a range of technical and organizational measures and continuously update them. If you suspect that your personal information has been misused, lost, or accessed without authorization, please let us know as soon as possible.

IV. Your Rights

As soon as personal data about you is processed, you are considered a data subject within the meaning of the GDPR. Consequently, you have the following rights vis-à-vis the data controller (i.e., us):

Every data subject has the right of access under Article 15 GDPR, the right to rectification under Article 16 GDPR, the right to erasure under Article 17 GDPR, the right to restrict processing under Article 18 GDPR, the right to object under Article 21 GDPR, and the right to data portability under Article 20 GDPR. The rights of access and erasure are subject to the limitations of §§ 34 and 35 of the BDSG (Federal Data Protection Act).

The right of access includes information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed or will be disclosed, the planned storage duration, the existence of a right to rectification, erasure, restriction of processing, objection, or data portability, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details.

You can request the immediate correction of incorrect or completion of your personal data collected by us at any time. You can also request the deletion of your personal data stored by us for the following reasons:

  • if your personal data is no longer needed for the purposes for which it was collected,

  • if you withdraw your consent and there is no other legal basis for processing,

  • if you object to the processing,

  • if your personal data has been unlawfully processed,

  • if your personal data must be deleted to comply with legal requirements.

 

Deletion cannot take place if the processing is necessary for the exercise of the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or for the assertion, exercise, or defense of legal claims. If this is not the case, we will delete your data upon request. We will generally also assume that it is in your interest for us to add your name to our list of individuals who do not wish to be contacted. This helps minimize the chance of future contact, should your data be collected separately under other circumstances.

 

Under certain circumstances, you may request that we restrict the processing of your personal data. This means that we will only store your data in the future and will not perform any further processing activities until: (i) one of the conditions listed below is resolved, (ii) you grant your consent, or (iii) further processing is necessary to assert, exercise, or defend legal claims, to protect the rights of others, or when processing is necessary due to legitimate public interest of the EU or a member state. You may request that we restrict the processing of your personal data under the following circumstances:

  • If you dispute the accuracy of the personal data we process about you. In this case, the processing of your personal data will be restricted until the accuracy of the data has been verified.

  • If you object to the processing of your personal data by us on the basis of our legitimate interests. In this case, you can request that the data be restricted while we review our reasons for processing your personal data.

  • If the processing of your data by us is unlawful, but you prefer to restrict the processing rather than have the data deleted.

  • If we no longer need to process your personal data, but you require the data to assert, exercise, or defend legal claims.

 

You also have the right to lodge a complaint with our Data Protection Officer or with a data protection supervisory authority (Article 77 GDPR in conjunction with § 19 BDSG). Generally, you can contact the supervisory authority at your usual place of residence or workplace, or the supervisory authority at the location of our company's headquarters.

 

You can revoke consent to the processing of personal data at any time by contacting us. This also applies to the revocation of consent declarations given to us before the GDPR came into effect, i.e., before May 25, 2018. Please note that the revocation only takes effect for the future. Processing carried out before the revocation is not affected. This also applies if we use your data for direct marketing purposes. Please also note the separate notice at the end of these data protection notices.

 

V. Your Right to Object Under Article 21 GDPR

1. Right to Object on a Case-by-Case Basis

You have the right to object, at any time, for reasons arising from your particular situation, to the processing of your personal data based on Article 6(1)(e) GDPR (data processing in the public interest) and Article 6(1)(f) GDPR (data processing based on a balancing of interests); this also applies to profiling based on these provisions under Article 4(4) GDPR. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is for the assertion, exercise, or defense of legal claims.

 

2. Right to Object to the Processing of Data for Advertising Purposes

 

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of your personal data for such advertising purposes; this also applies to profiling, insofar as it is related to direct marketing. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

 

The objection can be made informally and should preferably be sent by email to: datenschutz@van-grunsteyn.com.

Date: 01.07.2022

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