Privacy Policy
We appreciate your interest in our company and our services and want you to feel secure when visiting our website, including with regard to the protection of your personal data. As the protection of your privacy is also of particular concern to us, we take the protection of your personal data very seriously. The collection, processing, and use of personal data in connection with the operation of our website are governed by the European Union's data protection regulations and German data protection laws. When you use the Kontora Kapitalverwaltungs GmbH website, the following data is stored for technical and organizational reasons: The names of the pages accessed, the browser and operating system used, and additional information such as the date and time of access, search engines used, names of downloaded files, and your IP address. This technical data is evaluated anonymously and for statistical purposes only, as well as to improve the Kontora Kapitalverwaltungs GmbH website. It is not passed on to third parties. This anonymous data is stored separately from personal information on secure systems and does not allow any conclusions to be drawn about an individual person. Your personal data and privacy are therefore protected at all times.
I. Name and address of the controller
The controller 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 regulations is:
Kontora Kapitalverwaltungs GmbH
Jungfernstieg 51
20354 Hamburg
Tel.: +49 40 3290 888-67
Email: contact@kontora-kvg.com
II. Name and address of the data protection officer
The data protection officer of the controller is:
E-Mail: dsb-kunden@ibs-data-protection.de Tel.: 040-540 90 97 80
III. General information on data processing
1. Scope of personal data processing
We collect and use personal data from our users only to the extent necessary to provide a functional website and our content and services. The collection and use of personal data from our users is generally only carried out with the user's consent. An exception applies in cases where prior consent cannot be obtained for practical reasons and the processing of the data is permitted by law.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (DSGVO) serves as the legal basis for the processing of personal data.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfill 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 require the processing of personal data, Art. 6 (1) (d) DSGVO serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for processing.
3. Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in EU 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 further storage of the data for the conclusion or fulfillment of a contract.
IV. Provision of the website and creation of log files
1. Description and scope of data processing
Every time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:
(1) Information about the browser type and version used
(2) The user's operating system
(3) The user's Internet service provider
(4) The user's IP address
(5) Date and time of access
(6) Websites from which the user's system accesses our website
(7) Websites accessed by the user's system via our website
The data is also stored in our system's log files. This data is not stored together with other personal data of the user.
2. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 (1) lit. f DSGVO.
3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.
These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 (1) lit. f DSGVO.
4. Duration of storage
The data will be deleted as soon as it is no longer required for the purpose for which it was collected. In the case of data collection for the provision of the website, this is the case when the respective session has ended.
In the case of data stored in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymized so that it is no longer possible to assign them to the calling client.
5. Right to object and right to erasure
The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. Consequently, there is no possibility for the user to object.
V. Use of cookies
a) Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is accessed again.
We also use cookies on our website that enable us to analyze users' surfing behavior.
This allows the following data to be transmitted:
(1) Search terms entered
(2) Frequency of page views
(3) Use of website functions
The user data collected in this way is pseudonymized by technical measures. Therefore, it is no longer possible to assign the data to the user who accessed the website. The data is not stored together with other personal data of the users.
When visiting our website, users are informed about the use of cookies for analysis purposes via an information banner and referred to this privacy policy. In this context, there is also a note on how to prevent cookies from being stored in the browser settings.
When visiting our website, users are informed about the use of cookies for analysis purposes and their consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this privacy policy.
b) Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 (1) lit. a DSGVO, provided that the user has given their consent.
c) Purpose of data processing
Analytics cookies are used to improve the quality of our website and its content. Analytics cookies tell us how the website is used, enabling us to continuously optimize our offering.
These purposes also constitute our legitimate interest in processing personal data in accordance with Art. 6 (1) (f) DSGVO.
e) Duration of storage, right to object and right to erasure
Cookies are stored on the user's computer and transmitted to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.
VI. Use and application of Google Analytics (with anonymization function)
The controller has integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analytics service collects data about, among other things, which website a data subject came from (known as the referrer), which subpages of the website were accessed, how often a subpage was viewed, and how long it was viewed for. Web analytics is mainly used to optimize a website and to analyze the cost-benefit ratio 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. This addition is used by Google to shorten and anonymize the IP address of the data subject's Internet connection when accessing our website from a Member State of the European Union or from another State party to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services related to 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 placing the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is accessed, 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 process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently enable commission settlements.
The cookie stores personal information such as the time of access, the location from which access originated, and the frequency of visits to our website by the data subject. Each time you visit our website, 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 on this personal data collected via technical procedures to third parties.
The data subject can prevent the setting of cookies by our website at any time, as described above, by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting in the Internet browser used would also prevent Google from setting a cookie on the data subject's information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.
Furthermore, the data subject has the option of objecting to the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google, and of preventing such collection and processing. To do this, the data subject must download and install a browser add-on from the link tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information relating to visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the data subject's information technology system is deleted, formatted, or reinstalled at a later date, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.
Further information and Google's applicable privacy policy can be found at www.google.de/intl/de/policies/privacy/ and www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: www.google.com/intl/de_de/analytics/.
VII. 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 such processing is taking place, you may request the following information from the controller:
(1) the purposes for which the personal data is being processed;
(2) the categories of personal data that are being processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of 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 rectification or erasure of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information on the source of the data if the personal data is 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 these cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
You have the right to request information on whether personal data concerning you is being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.
2. Right to rectification
You have the right to request the controller to correct and/or complete your personal data if it is inaccurate or incomplete. The controller must make the correction immediately.
3. Right to 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 oppose the erasure of the personal data and request the restriction of their use instead;
(3) the controller no longer needs the personal data for the purposes of the processing, but you need it for the establishment, exercise, or defense of legal claims; or
(4) you have objected to processing pursuant to Article 21(1) of the DSGVO and it is not yet clear whether the legitimate grounds of the controller override your grounds.
If the processing of personal data concerning you has been restricted, such data may – apart from its storage – only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
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 delete
You may request that the controller delete your personal data without delay, and the controller is obliged to delete this data without delay if one of the following reasons applies:
(1) The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
(2) You withdraw your consent on which the processing was based in accordance with 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 Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
(4) The personal data concerning you has been processed unlawfully.
(5) The erasure of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
(6) The personal data concerning you has been collected in relation to information society services offered in accordance with Art. 8(1) 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 Art. 17 (1) DSGVO, it shall take reasonable steps, including technical measures, taking into account the available technology and implementation costs, to inform controllers who process the personal data that you, as the data subject, have requested them to delete all links to this personal data or copies or replications of this personal data.
c) Exceptions
The right to erasure does not apply if processing is necessary
(1) for exercising the right of freedom of expression and information;
(2) for compliance with a legal obligation which requires processing by 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 of official authority vested in the controller;
(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 DSGVO;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of this processing, or
(5) for the establishment, exercise or defense of legal claims.
5. Right to information
If you have asserted your right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort.
You have the right to be informed by the controller about these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable format. You also have the right to transmit 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 (1) (a) DSGVO or Art. 9 (2) (a) DSGVO or on a contract pursuant to Art. 6 (1) (b) DSGVO, and
(2) the processing is carried out using automated means.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.
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 of objection
You 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 based on Article 6(1)(e) or (f) of the DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless the controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.
If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the option, in connection with the use of information society services, to exercise your right to object by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.
8. Right to revoke the data protection consent form
You have the right to revoke your declaration of consent under data protection law at any time. Revoking your consent does not affect the legality of the processing carried out on the basis of your consent prior to 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 entering into, or performance of, a contract between you and the controller,
(2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
(3) is based on your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 (1) DSGVO, unless Art. 9 (2) lit. a or g applies and appropriate measures have been taken to protect your rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take appropriate measures to safeguard your rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.
10. Right to lodge a complaint with a supervisory authority
Without 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 habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to 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 of the DSGVO.