Last updated: 25 May 2018
Your trust is important to us, the ValueTrust Financial Advisors SE and the ValueTrust Financial Advisors GmbH (“ValueTrust”, “we” or “us”). Therefore we make sure that we handle your data with care. Please read through this Privacy Notice carefully. In the following we describe which data we process for which purpose, on which legal basis (see 2.) and for how long we will do so (see 3.). We also explain to you your rights in this respect (see 4. and 5.)
1. Application of this Privacy Notice and responsibility
1.1 This Privacy Notice applies to any operation or set of operations, in particular, collection, processing, storage, adaptation, retrieval and use (“Processing”) of your personal data in connection with our services.
1.2 Within the meaning of the relevant data protection laws, in particular the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz) ValueTrust Financial Advisors SE is the data controller responsible for the Processing in connection with both this website and business relationships with ValueTrust Financial Advisors SE. ValueTrust Financial Advisors GmbH is responsible for the Processing in connection with its own business relationships.
1.3 Should you have any questions or comments on this Privacy Notice or generally on data protection please direct them to our data protection officer:
2. Processing your personal data
In this chapter we set out when we process your personal data for what purpose and on what legal basis.
2.1 Data processing required for technical reasons
For technical reasons every time you access our website certain data is sent from your computer to our web hosting provider. Our web host stores the information such as date and time of contact with our website, type of browser and browser settings, website last visited, data volume transferred and access status (data transferred, data not found, etc.) in log files. This data in itself is not as a rule personal data within the meaning of the GDPR. According to our web host IP addresses are stored anonymously (as the last three figures are removed from IPv4 addresses and the last eight from IPv6 addresses). Information on directory protection users are anonymised after one day. Error logs – which record incorrect page views – include not only the error messages but the IP address of the user and, depending on the error, the website contacted. Our web host processes this data on our behalf and grants us access to the log files to enable us to display the website correctly and assure its stability and security. The legal basis for this data processing is Art. 6 (1) f GDPR.
You can receive our newsletter or offers by SMS, email, phone or post. When registering for our newsletter or offers we will ask for your consent unless we already have a business relationship with you on the basis of which we may send you information on similar services provided you have not objected thereto. As far as no consent is required, legal basis for this Processing is Art. 6 (1) f GDPR. How you can object or, if required, withdraw your consent is set out under 4. below. You can also easily unsubscribe to the newsletter via the link at the end of each newsletter.
2.3 Your contact query
If you contact us by calling us, sending us an email, sending us your application, because you would like to apply for a position advertised on our website, or by using a contact form we provide, we will process your personal data (e.g. your name, email address and other information which you have provided us) in order to process your query. Due to the fact that ? as providers of this website ? we are obliged to provide effective contact options, as a rule, Processing in this regard is based on a statutory obligation within the meaning of Art. 6 (1) c GDPR. If the query relates to the conclusion of a contract Art. 6 (1) b GDPR (in the context of employment read in conjunction with section 26 (1) German Data Protection Act) provides the legal basis.
2.4.1 Functional cookies
User-friendliness, individual appearance and efficiency of our website depend on our being able to recognise your browser when you return to our website. This is why we, or providers with whom we cooperate, use technically essential cookies in order to secure and optimise the functionality of the page. The legal basis for the Processing of is Art. 6 (1) f GDPR.
2.4.2 Google Analytics
Google will use this information on our behalf to analyse your usage of the website in order to compile reports on website activities and to provide further services to us relating to the usage of the website and the internet. According to Google your IP address will not be merged with other data Google holds about you.
We process this data on the basis of our legitimate interest pursuant to Art. 6 (1) f GDPR in the ongoing improvement of our offer. You can prevent the data generated by the cookie regarding your use of the website (including your IP address) from being collected and sent to Google and the Processing of the data by Google by downloading and installing the browser plug-in available through the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
2.4.3 Google Maps
2.5 Statutory obligation and other data processing
In certain situations we are obliged under law or subject to official or court instruction to process your personal data. This is the case where tax law is concerned for example. In this case the data processing is based on Art. 6 (1) c GDPR.
If necessary, we are also entitled, to process your data in connection with the assertion of rights. In this case as a rule we have a legitimate interest within the meaning of Art. 6 (1) f GDPR.
3. Erasure and storage terms
We process your data only as long as necessary for the respective purpose. Beyond this period data can be stored for restricted grounds set out in statute, for example if this is required for legal action. Shorter retention may apply if you demand erasure of the data.
We erase your data in principle after the following periods:
- Error logs which record incorrect views of our website will be erased after seven days.
- We delete your data as an applicant at the latest after six months after your application was rejected.
- We delete data relating to your contact queries at the latest after one year.
4. Withdrawal and Objection
Of course, consent granted can be withdrawn at any time free of charge with effect for the future. All you need to do is send a communication in text form, e.g. by
- letter to ValueTrust Financial Advisors SE, Theresienstraße 1, 80333 Munich, Germany
- fax to +49 89 388 790 444, or
- email to firstname.lastname@example.org.
- letter to ValueTrust Financial Advisors GmbH, Schottenring 16, 1010 Vienna, Austria,
fax to +43 1 53712 4000, or
email to email@example.com.
This also applies to your objection – which may be made at any time – to the use of your personal data based on Art. 6 (1) f GDPR.
In order to exclude misuse it may be necessary that you provide proof of your identity. We will notify you if this applies.
5. Your rights under the GDPR
You are entitled to information about the personal data relating to you which we process, its rectification or erasure. You can also demand a restriction on Processing or, as already set out under 4., you may exercise your right of objection. You also are entitled to data portability.
You may exercise your rights via the following contact options, depending on who your contractual partner is:
By letter to ValueTrust Financial Advisors SE, Theresienstraße 1, 80333 Munich, by phone via +49 89 3887900, or by email to firstname.lastname@example.org.
By letter to ValueTrust Financial Advisors GmbH, Schottenring 16, 1010 Vienna, by phone via +43 1 537 124 838, or by email to email@example.com.
Finally you can also file complaints about our data processing activities with a regulatory authority.
6. Categories of recipients and international data transfer
We work with cloud service providers, a provider of customer relationship management systems (HubSpot, Inc.) and a provider of a project management system which process personal data on our behalf. We also cooperate the newsletter service rapidmail GmbH which sends newsletters in our name. HubSpot, Inc., 25 First St, 2nd Floor, Cambridge, MA 02141, USA, stores data worldwide, including in the USA. For this purpose HubSpot, Inc. has subjected itself to the EU – US Privacy Shield Framework.
Our service providers and we process personal data within the EU unless we have expressly stated otherwise in this Privacy Notice – in particular with regard to Google and HubSpot.
ValueTrust Financial Advisors SE, Theresienstraße 1, 80333 Munich, Germany, +49 89 388790 0, firstname.lastname@example.org
ValueTrust Financial Advisors GmbH, Schottenring 16, 1010 Vienna, Austria, +43 1 537 124 838, email@example.com
© 2018 ValueTrust Impressum