PRIVACY POLICY

Last updated: August 1, 2020

 

Thank you for your interest in ValueTrust’s offer. We, ValueTrust Financial Advisors SE, ValueTrust Financial Advisors GmbH and  ValueTrust Financial Advisors Switzerland AG (hereafter “ValueTrust”, “we” or “us”) consider the data protection requirements of the European Data Protection Basic Regulation (GDPR) in our processes and procedures.

Here we inform you for what purpose and on what legal basis we process your personal data and for how long and what rights you are entitled to with regard to data processing.

 

Responsible
According to Art. 4 No. 7 GDPR responsible for the data processing in connection with this website and with the respective business relations is:

ValueTrust Financial Advisors SE, Theresienstraße 1, 80333 Munich, Germany
Phone +49 89 388 790 0, E-mail info@value-trust.com

ValueTrust Financial Advisors GmbH, Schottenring 16, 1010 Vienna, Austria
Phone +43 1 537 124 838, E-mail info@value-trust.com

ValueTrust Financial Advisors Switzerland AG, Bahnhofstrasse 52, 8001 Zurich, Switzerland
Phone +41 44 500 5900, E-mail info@value-trust.com

Contact for your rights
You can contact the data protection representative of the ValueTrust Group by e-mail at datenschutzbeauftragter@value-trust.com.

Subject of data protection
The subject of data protection is personal data. According to Art. 4 No. 1 GDPR, this is all information relating to an identified or identifiable person. This includes information such as first and last names, e-mail addresses, but also usage data such as your IP address.

Extent of the processing of personal data
We strictly observe the principle of the purpose-related use of data. All personal data will only be processed for the purposes stated in this data use information.

In the following, we have compiled the most important information on typical data processing, separated according to data subject groups. For certain data processing operations that only concern specific groups, the information obligations are fulfilled separately.

If the term “data” is used in the text, this refers exclusively to personal data within the meaning of the GDPR.

 

I. Visitors to our website
II. Customers, business partners and their employees
III. Recipients of newsletters and event invitations
IV. Participants of events
V. Interested parties and other communication partners
VI. Applicants for employment
VII. Social Media Buttons (recommendation buttons)
VIII. Google Maps
IX. Our service providers
X. What else you should know – Your rights

 

I. Visitors to our website

If you visit our site only for information about the ValueTrust Group, we process your personal data only to the extent necessary to display our website on your end devices on the Internet in the best possible way. The use of the website is generally possible without providing personal data.

We say ” generally ” because we process your IP address for a short time to enable you to view the website.

A. Server log data
In computer networks, the IP address, also known as Internet Protocol Address, is an address through which web servers or individual terminal devices can be addressed and reached. In order that the data packets of which the page www.value-trust.com consists can be assembled on your mobile device and displayed as a web page, two IP addresses are required, yours and ours.

For our web server to fulfill your data request, our web server must know your IP address. Therefore, it has to process your IP address. For this purpose, our web server receives information about which website your request came from, which website or file was called up by you and when (date, time of the request, time zone), which browser and which operating system you used and in which language your browser was set. This data is usually automatically stored all together in a log file, also called log file.

1. Purpose
Purpose of data processing is thus the secure presentation of the ValueTrust Group and its offerings on the Internet.

2. Legal basis
Legal basis for the processing is Article 6(1)(f) DPA. Our legitimate interest in data processing lies in the operation of a functional, secure and optimised Internet presence and in ensuring the security of our information technology systems.

3. Storage duration
As a matter of principle, we do not store your IP address in the log files. Instead of the actual IP address, only the number 127.0.0.* will appear there after one day.

Your IP address, shortened as described above, will be saved by our web server for a maximum of two months after your visit to ensure the secure and functional operation of the website. It will only be used to avert danger (in the event of attacks) and to improve the Internet offer and will not be passed on to third parties.

You cannot use our website without us processing this personal data, in particular the IP address. Consequently, you cannot object to the data processing.

4. Data transfer
Protocol and communication data will only be passed on to third parties if special circumstances arise. In case of suspicion of a crime or in preliminary proceedings, we may transfer data to the police and public prosecutor’s office.

B. Cookies and analysis
In order to optimize your visit to our website, we use cookies, and for analysis of usage data the range analysis service of Google Ireland Limited.

1. Cookies in general
Cookies are text files which are stored in your browser and by which your computer can be identified and recognised when you visit our site again. They do not interfere with the operating system of your computer.

You can basically set your web browser to prevent cookies or so-called “third party cookies” from being stored on your computer. To do this, you can deactivate the corresponding option in the system settings of your browser. Under certain circumstances, however, individual functions of our offer may then not be usable.

Here you can inform yourself about the setting options for the most frequently used browsers:

2. Overview of cookies

a) Functional cookies
The usability, individual presentation and efficiency of our website depends on our ability to recognise your browser even after you have been to another website. For this reason we use so-called technically necessary cookies. With the help of these we can ensure the functionality of the site and optimise it for your browser. With their help we can also ensure the security of our systems and counteract IT fraud.

Consequently, you cannot object to this processing. However, you can deactivate these cookies by changing the respective settings of your browser.

(1) Purpose
Purpose of data processing is thus the secure and optimized presentation of the ValueTrust Group and its offerings on the Internet as well as ensuring IT security and fraud prevention.

(2) Legal basis
The legal basis for the processing is Article 6(1)(f) DPA. Our legitimate interest in data processing lies in the operation of a functional, secure and optimised Internet presence.

b) Usage analysis
We use cookies and analysis technologies that enable us to perform a statistical analysis of your use of our website. We use the usage analysis information to evaluate the use of our website and to compile reports on website activity in order to measure the success and reach of our websites.  This allows us to better tailor our online presence to your needs and interests and to offer you content that better meets these needs and interests. The processing of this data is carried out on our behalf.

(1) Google (Universal) Analytics
We use Google (Universal) Analytics on our website. Universal Analytics is a web usage analysis service provided by Google LLC (“Google”). Google Analytics uses cookies which are stored on your computer or mobile device and which enable an analysis of your use of our website.

Our website activates IP-anonymisation in order to shorten the processing of your IP-address and to exclude the possibility of personal references. The information generated by the cookies about your use of our website (including your shortened IP address) is transferred to Google servers and stored there. Google servers can also be located in the U.S.A. We have concluded the EU standard contractual clauses with Google, so that even in exceptional cases there is an adequate level of protection for personal data under data protection law.

In order to carry out the range measurement, we use the following cookies:
_ga………. Duration of validity: two years
_gid……… Duration of validity: one day
_gat……… Duration of validity: End of session

You may object to the collection of data generated by the cookies and related to your use of the website (including your IP address) and the processing of this data. To do so, you must download and install the browser plug-in available here.

(2) HubSpot Inc.
We use HubSpot on our website. HubSpot is a web analytics service of HubSpot Inc. (“HubSpot”). HubSpot also uses cookies, which are stored on your computer or mobile device, to help us analyze how you use our website.

A data transfer to the U.S.A. through HubSpot cannot be excluded. We have concluded the EU standard contractual clauses with HubSpot, so that even in exceptional cases there is an adequate level of protection for personal data in accordance with data protection law.

You can generally prevent the storage of cookies by adjusting your browser software accordingly, see also the explanations above under B. I. Cookies in general. However, we would like to point out that in this case you may not be able to use all functions of our website to their full extent.

(3) Purpose
Purpose of the evaluation of user behaviour on our website is to ensure that it is tailored to the needs of the user. A change of these purposes is not planned.

(4) Legal basis
The legal basis for the analysis of usage behaviour is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in always designing and optimising our online presence in line with requirements.

(5) Data transfer
This data is passed on to companies within our group of companies.

 

II. Customers, business partners and their employees

If you are our customer or business partner or an employee of one of our customers or business partners, we process your data in order to establish and implement contractual relationships with you or with your company and to comply with legal requirements. You are a customer or business partner or an employee of our customers or business partners, both legally and contractually obliged to provide us with the relevant data. Without the corresponding information, a customer or business relationship with us can neither be established nor carried out.

A. Purpose
We process your data to establish and carry out business relationships. A change of these purposes is not planned.

B. Legal basis
The legal basis for data processing in the context of contracts with natural persons is Art. 6 para. 1 lit. b) GDPR, because it serves the preparation and execution of contracts. In the case of contracts with legal persons, Art. 6 para. 1 lit. f) GDPR forms the legal basis. In this context, our legitimate interest lies in being able to communicate with contract-relevant contact persons.

Art. 6 para. 1 lit. c) GDPR always forms the legal basis for data processing when we are legally obliged to process your data, which is the case, in particular within the framework of tax and commercial law regulations. In the event of any examination, enforcement or rejection of claims, Art. 6 para. 1 lit. f) GDPR forms the legal basis for data processing. In this context, our legitimate interest lies in the enforcement of claims or in the defence against claims.

C. Data transfer
The recipients of your data for the processing of payments are banks. As far as we are obliged or entitled to transfer data, authorities and offices can be recipients of your data within the scope of their tasks. In individual cases, your data may be transferred to collection service providers, lawyers and courts.

D. Data storage
All data relevant to contract and accounting will be retained in accordance with the retention periods under tax and commercial law for a period of at least ten calendar years after the end of the contract.

 

III. Recipients of newsletters and event invitations

A. General information
If you receive our newsletter or event invitations, we need your e-mail address. Otherwise we cannot send you the newsletter or event invitation. Our newsletters and event invitations are always personalized, i.e. we always address you personally. In order for us to address you personally in our newsletters and event invitations, we also need your salutation, as well as your first and last name.

B. Double-Opt-In for verification of the e-mail address and proof of consent 
When you subscribe to the mailing list on our site, we will send you a link and ask you to confirm the e-mail address you entered using the so-called double opt-in to ensure that it is your correct e-mail address.

If we do not maintain an ongoing business relationship with you, on the basis of which we are legally permitted to send you information on similar services, we will ask for your consent. In this case, the exercise of the double opt-in also serves as proof of your consent.

Only after clicking on the confirmation link, you will be added in our distribution list and CRM.

In this case, we will save your registration and confirmation time in order to log your registration and, if necessary, to prove your e-mail verification or your consent.

In our CRM we store the mandatory data, i.e. your e-mail address, your title, your first and last name as well as the data you have voluntarily provided during registration. Providing the mandatory data is essential for receiving newsletters and event invitations. Without the provision of this data, we will not be able to send you newsletters and event invitations.

C. Analysis of opening and clicking behavior
To send our newsletter we use the newsletter tool which is part of our CRM. It enables us to record whether you have opened our newsletter and which links in our newsletters you have clicked on.  For this purpose, a so-called tracking pixel is integrated into our newsletter. This analysis of opening and clicking behaviour enables us to automatically delete recipients who have not used our newsletter for a longer period of time from the distribution list. It also enables us to understand which content is of interest to you so that we can adapt the information mails to your needs and interests.

By registering for our newsletter and clicking the confirmation link, you expressly agree that we may collect your data as described above. Without this consent you will unfortunately not be able to use our newsletter and the possibility to receive event invitations.

D. Unsubscription
You can of course object to the further sending of information mails and the analysis of the opening and clicking behaviour at any time by unsubscribing from the information mails. To do so, click on the unsubscribe button which you will find at the end of each information mail. Alternatively you can also contact info@value-trust.com.

E. Opening the e-mail in the browser
If you access our information mail for correct display via the link provided in the e-mail in your browser, the e-mail will be opened on our website. The web analysis tool of HubSpot as well as Google Analytics is used for this purpose. You can of course also use the usual measures to prevent the tracking.

F. Purpose
We process your data for the purpose of sending personalised newsletters and event invitations with content that is of interest to you as the recipient, to verify the accuracy of your e-mail address and to prove your consent. A change of these purposes is not planned.

G. Legal basis
We base the processing of your data in the context of sending newsletters and event invitations on Art. 6 para. 1 lit. f) GDPR, if you are our customer or business contact or contact person at a customer or business contact, otherwise your consent under Art. 6 para. 1 lit. a) GDPR forms the legal basis for the data processing. Our legitimate interest within the meaning of Art. 6 para. 1 lit. f) GDPR lies in communicating with customers and business contacts.

The storage of your registration and confirmation date is also carried out in accordance with Art. 6 para. 1 lit. f) GDPR. In this respect, our legitimate interest lies in being able to prove, in the event of any legal disputes, that you have subscribed to the mailing list for the dispatch of newsletters and event invitations. With the double opt-in procedure, we also take your legitimate interest into account by ensuring that you have not been registered by unauthorised third parties.

The evaluation of your opening and clicking behaviour is based on your consent pursuant to Art. 6 para. 1 lit. a) GDPR.

H. Cancellation
Data on information mails are deleted when you unsubscribe.

 

IV. Participants of events

If you take part in one of our events, we usually process your title, your first and last name, your contact data. Our events are usually free of charge. If, however, an event is subject to a charge, we would process your billing data in addition to the above-mentioned data. At our events, we usually also make image and sound recordings. The provision of data is contractually binding for participation in events. Participation in our events is not possible without providing the contractually relevant data.

The production of image and sound recordings is not obligatory for participation in the event. If you do not wish to have any picture and sound recordings, please inform our staff at the event location.

A. Purpose
We will process your data for the purpose of holding the event. We process the image and sound recordings for the documentation of the event. We use the resulting recordings for the purpose of press and public relations work. A change of these purposes is not planned.

B. Legal basis
Legal basis for the processing of your data as a participant is Art. 6 para. 1 lit. b) GDPR, because your data is necessary for the fulfilment of the contract for the performance of the respective event. Furthermore, we process your data in accordance with Art. 6 Para. 1 lit. c) GDPR within the framework of the legal obligations imposed on us, in particular on the basis of tax and commercial law regulations.

We base the production and publication of image and sound recordings on Art. 6 para. 1 lit. f) GDPR. Our justified interest is based on the fact that we document the events we hold and that we are able to present our group of companies through press and public relations work.

C. Data transfer
For the purpose of press and public relations work, we transmit image and sound recordings of our events to journalists, media companies, press and photo agencies and social media platforms and publish them in printed or digital form.

D. Cancellation / Storage
Picture and sound recordings of our events as well as our publications are usually archived and therefore not deleted.

All data relevant to contracts and bookkeeping are retained in accordance with tax and commercial law retention periods for a period of ten calendar years after the end of the contract.

 

V. Interested parties and other communication partners

If you contact us by phone, by sending us an e-mail, a fax or a letter or by using the contact form provided on our website, we will process your data to deal with your request. The provision of data is necessary in order to process your request. Communication is not possible without the provision of data.

A. Purpose
We therefore process your data for the purpose of effective communication. A change of this purpose is not planned.

B. Legal basis
The legal basis for the processing of your data is Article 6 paragraph 1 letter f) GDPR. Our legitimate interest lies in being able to communicate effectively with interested parties and other communication partners. Furthermore, as the operator of this website we are legally obliged to provide you with an effective means of contact. Therefore, Art. 6 para. 1 lit. c) GDPR in conjunction with § 5 para. 1 no. 2 TMG forms the legal basis for the processing of your data, provided that you use the form provided to contact us.

C. Cancellation 
Anfragen und Kommunikation werden nach zehn Kalenderjahren automatisch gelöscht.

 

VI. Applicants for employment

If you apply for a job with us, we process your personal data (so-called application data) only to the extent necessary to decide whether to establish an employment relationship with you. The provision of data is necessary for applicants. An application is not possible without the provision of data.

Access to or entry to your application data is only granted to employees who are authorised to make decisions. As a rule, these are members of the management, employees of the personnel department as well as department or team leaders.

We ask you to send us your application documents only via our career portal. Application documents that reach us by other means will be deleted without being processed.

We use a personnel administration tool, which is operated by our service provider, to operate our career portal. This service provider processes your personal data on our behalf and in accordance with our instructions within the European Union. We also use Universal Analytics, the web usage analysis service of Google LLC. for the purpose of measuring the range of coverage and designing the portal to meet your needs. You can find more information on Universal Analytics under I. B. 2. b).

A. Purpose
The processing of your application data serves the purpose of deciding whether to establish an employment relationship. A change of this purpose is not planned.

B. Legal basis
The processing is thus carried out within the framework of pre-contractual measures for an employment relationship with us which is the aim of the application. The legal basis for this is Art. 6 para. 1 lit. b), 88 GDPR in conjunction with Art. 26 para. 1 sentence 1 and para. 8 sentence 2 BDSG.

C. Cancellation / Storage
Your personal application data will be deleted in the case of advertised positions – regardless of the outcome of your application – after six (6) months after a decision has been made to fill the position.

After a possible rejection, you have the possibility to agree to a storage period exceeding the abovementioned deletion period of six (6) months, provided that you are also interested in other locations.

If you give us such permission, we will store your application data for a period of one (1) additional year. In this case, you may revoke your consent at any time. If you revoke your consent, your application data will be deleted accordingly. The legal basis for processing beyond the normal retention period is Art. 6 para. 1 lit. a) GDPR.

If you send us a speculative application, we will store your application data for a period of one (1) year, unless you clearly state in your application that you do not wish to do so.

 

VII. Social Media Buttons (recommendation buttons)

A. LinkedIn and XING

1. Recommendation buttons
We maintain appearances in the “social media”. They are part of the public relations work of the ValueTrust Group. It is the ValueTrust Group’s endeavor to inform and exchange information with interested parties in a target group-oriented manner. Social media enable us to establish electronic contact quickly and thus to communicate directly via the media of your choice, as required by § 5 (1) No. 2 TMG.

On our website, recommendation buttons from LinkedIn and XING are integrated. The links to these platforms are integrated in such a way that your personal data is only sent to the respective service when you click on the recommendation button (so-called Shariff solution).

We have no influence on which data is transmitted to LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) and to Xing (New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany) after clicking on it. You use the platforms and their functions on your own responsibility. This applies in particular to the use of the interactive functions, such as commenting on, sharing or rating our contributions as well as liking our company site. Most interactive functions are reserved for registered and logged in users.

2. Your rights
You have the following rights with regard to the processing of your personal data: right of access; right of rectification; right of erasure; right to limit processing; right of opposition; right of transferability and the right to complain to the competent data protection authority about unlawful processing of your personal data. Please read in detail the explanations.

We do not have complete access to your personal data. You should therefore contact the provider of the respective platform directly when asserting your claim. This provider has access to the personal data of its users and can take the appropriate measures and provide information. We are happy to support you if you still need help. Please contact info@value-trust.com for this purpose.

a) Objection on LinkedIn
For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information:

b) Objection on Xing
For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information:

B. Joint accountability
In the following cases we are jointly responsible according to Art. 26 GDPR.

LinkedIn
As the operator of a company page on the professional social network LinkedIn (hereinafter referred to as “LinkedIn page”), we, together with the operator of this network, are responsible in the sense of Art. 4 No. 7 GDPR. LinkedIn is operated by LinkedIn Ireland Unlimited Company, with its registered office at Wilton Plaza in Wilton Place Dublin 2 in Ireland. When you visit our LinkedIn site, personal data is processed by those responsible, i.e. by us and by LinkedIn.

We have entered into an agreement with LinkedIn that governs, among other things, the terms and conditions of use of our LinkedIn site. The LinkedIn Terms of Use and the other terms, conditions, and policies listed at the end of this agreement govern your use of the LinkedIn site.

In connection with the operation of our LinkedIn site, we use the Page Insights function to obtain statistical information about users. For this purpose, LinkedIn, according to its own information, stores a cookie on the end device of registered users who visit our LinkedIn site. When you visit our LinkedIn site, LinkedIn stores a cookie on your device to enable us to statistically evaluate your visit. The information stored in the cookie is processed by LinkedIn, especially when you, as a user, visit LinkedIn services and services provided by other companies that use LinkedIn services. For more information about LinkedIn’s use of cookies, please refer to their cookie policy.

In the context of statistical analysis, we use the filters provided to us by LinkedIn to determine the categories of data according to which LinkedIn provides us with anonymised statistics. The following criteria or categories are available to us in anonymised form for evaluating your activities on our LinkedIn site, provided that you as a user have provided the relevant information:

  • Place (place of work or residence)
  • Field of work
  • Career stage
  • Industry
  • Company size
  • Age range
  • Gender
  • Language
  • Mobile or stationary page view (YouTube additionally individual device types)
  • Interactions in the context of posts (e.g. reactions, comments, shares, clicks, views, video usage time)
  • Time of use

 

VIII. Google Maps

If you click on our address, you will get to Google Maps. The link to Google Maps is also integrated so that your personal data is only sent to Google when you click on the address.

Again, we have no control over what information is sent to Google Maps (Google Ireland Ltd., with its principal place of business at Gordon House, Barrow Street, Dublin 4, Ireland) after clicking on it. In accordance with Google’s privacy policy, we assume that any transfer of personal data, including the processing thereof, to servers of Google LLC in the U.S.A. (1600 Amphitheatre Parkway Mountain View, California 94043).

 

IX. Our service providers

We use service providers for the performance of services, especially for the provision, maintenance and servicing of IT systems. Our service providers process your personal data, unless we have expressly described otherwise in this privacy policy – especially in the case of LinkedIn – on our behalf and in accordance with our instructions within the European Union.

We have concluded the EU standard contract clauses with the US providers HubSpot, Google and LinkedIn. We would like to point out that these providers thus undertake to comply with EU data protection standards, so that an adequate level of protection for your personal data exists under data protection law.

 

X. What else you should know – Your rights

You have the right to obtain confirmation as to whether or not data concerning you are being processed and to receive information about such data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction on the processing of the data.

You have the right to demand that the data concerning you that you have provided us with is made available to you in accordance with Art. 20 GDPR, as well as the right to demand its transfer to other responsible parties.

Under Art. 7 para. 3 GDPR, you have the right to revoke any consent you have given at any time with effect for the future. If you revoke your consent, we may no longer continue the data processing based on this consent for the future. Please send your possible revocation to info@value-trust.com.

If we process your data in accordance with Art. 6 Para. 1 letter f) GDPR on the basis of legitimate interests, you can object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time, provided there are reasons for doing so arising from your particular situation. However, we cannot always comply with your objection, e.g. if legal provisions oblige us to process data.

If your objection is directed against direct advertising, you have a general right of objection. In this case, your right of objection is implemented without having to provide information on a specific situation. Please send your objection to  info@value-trust.com.

Under Art. 77 GDPR they also have the right to lodge a complaint with the competent supervisory authority. The authority responsible for us is the Bavarian State Office for Data Protection Supervision. However, you may also contact the supervisory authority of your usual place of residence or workplace.

You can reach us as follows:

  • Postal address: PO Box 1349, 91504 Ansbach, Germany
  • Address: Promenade 18, 91522 Ansbach, Germany
  • Phone: +49 (0) 981 180093-0
  • Fax: +49 (0) 981 180093-800
  • E-mail: poststelle@lda.bayern.de
  • Web: www.lda.bayern.de