1. Introductory remarks
Data is the basis for us to provide an excellent service. Our most important capital, however, is the trust of our contractual partners. Protecting the data provided by you and collected by us when using our services therefore has the highest priority for us. Therefore the observance of the legal regulations to the data security is self-evident for us.
2. Scope of the processing of your data
4. Processing of your data
For the purposes mentioned above, we collect the following personal data about you:
– Date of birth,
– phone number,
– bank details,
– identity card details and
However, this data will only be used if you have given us your consent or if we need it to fulfil our contractual obligations.
Your address, e-mail address and telephone number will also be used to send you promotional messages and mailings about investment projects with information. We will also use your email address to periodically send you newsletters with the same and similar content as the promotional messages and mailings. You can find more information on the subject of “e-mail newsletters” in point 5.
The following information will inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you agree to the receipt and procedures described.
Content of newsletter
We send newsletters, e-mails and other electronic notifications with information (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Our newsletter contains general information on Paul Putz & Partner Management Consultants GmbH as well as current information on our investment projects.
Double-Opt-In and logging
The registration to our newsletter takes place in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with external e-mail addresses.
The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with MailChimp are logged.
Use of the “MailChimp” dispatch service provider
The newsletter is sent via “MailChimp”, a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
The e-mail addresses of our newsletter recipients, as well as their further data described in the context of these notes, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, MailChimp can use this data according to its own information for the optimization or improvement of its own services, e.g. for the technical optimization of the dispatch and display of the newsletter or for economic purposes, to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them or pass them on to third parties.
To subscribe to the newsletter, we ask you to provide your email address and your first, last name and country of origin. Alternatively, you can register for the newsletter during the investment process. All you have to do is click on the box for newsletter registration at the end of the investment questionnaire.
Statistical survey and analysis
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are collected. This information is used for the technical improvement of the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times.
Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor MailChimp’s aim to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Online access and data management
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consents to its dispatch via MailChimp and the statistical analyses expire. A separate revocation of the dispatch via MailChimp or the statistical evaluation is unfortunately not possible.
You will find a link to cancel the newsletter at the end of each newsletter or you can write to us at email@example.com to cancel the newsletter.
6. Processing by contract data processors and transfer of your data to third countries or international organisations
Use of Google Analytics
We use Google Analytics to analyze website usage. The data obtained from this is used to optimise our website and advertising measures.
Google Analytics is a web analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States). Google processes the data for website use on our behalf and is contractually obliged to take measures to ensure the confidentiality of the processed data.
During your visit to our website the following data will be recorded:
– Pages viewed
– Orders incl. turnover and ordered products
– Your behaviour on the pages (e.g. clicks, scrolling behaviour and length of stay)
– Your approximate location (country and city)
– Your IP address (in abbreviated form, so that no unambiguous assignment is possible)
– Technical information such as browser, Internet provider, terminal device and screen resolution
– Source of your visit (i.e. via which website or advertising medium you came to us)
This data is transferred to a Google server in the USA. Google will comply with the privacy provisions of the EU-US Privacy Shield Agreement.
Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you on future website visits.
The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remain stored in aggregated form for an indefinite period.
You can prevent this by setting your browser so that no cookies are stored.
Use of Google reCAPTCHA
On our website we use the service reCAPTCHA of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). The query serves the purpose of differentiating the input by a person or by automated, mechanical processing. Your input will be transmitted to Google for further use. In addition, the IP address and any other data required by Google for the reCAPTCHA service will be transmitted to Google. This data will be processed by Google within the European Union and possibly also in the USA. For data transfers to the USA, the European Commission has issued an adequacy decision, the “Privacy Shield”. Google participates in the “Privacy Shield” and has submitted to the guidelines.
The processing is carried out on the basis of Art. 6 para. 1 lit. f DSGVO in the legitimate interest of protecting our website from automated spying, misuse and SPAM.
8. Social Media Plug-Ins
Our websites may also provide button links to plugins from various social networks, including “Facebook”, “Google Plus”, “Twitter”, “LinkedIn”, “Xing” and more, “Instagram,” “Pinterest,” “WeChat,” “YouTube,” “Vimeo,” “Snapchat,” “Slideshare,” and “WhatsApp”. Personal data (e.g. IP address) can only be collected by the operators of the respective social networks when the respective buttons are pressed. By pressing these buttons, you consent to the transmission of data to the operators of these platforms. We have no influence on the collection of data by the respective operators of social networks. Information on the extent and use of the data collected can be found in the privacy policies of the respective social networks.
9. Data subjects’ rights
- Right of disclosure
You have the right to request confirmation as to whether personal information is being processed. If this is the case, you have the right of disclosure of this personal information.
- Right of correction
You have the right to request the correction of incorrect data. Insofar as this is necessary for the achievement of the purpose of a data processing, you also have the right to demand the completion of incomplete data.
- Right of deletion
You have the right to request the deletion of your personal data. If no legally recognized reason speaks against deletion, we will delete your personal data immediately.
- Right of restriction of processing
You have the right to demand the restriction of processing under the following conditions:
– You deny the accuracy of your personal information;
– Instead of deleting illegally processed data, you require their use to be restricted;
– You need processed data to assert, exercise or defend legal claims;
– When exercising the right to object, for the duration of the clarification, whether justified reasons require further data processing.
- Right of objection
If data processing is required to safeguard legitimate interests of us or a third party, you have the right to object to the processing for reasons that arise from your particular situation. If there are no compelling legitimate reasons for further processing that outweigh your interests, rights and freedoms and no further processing is required to assert, exercise or defend any legal claim, we will immediately delete your information.
- Right of data transfer
If we use automated data processing based on your consent or to fulfil a contract with you, you have the right to receive the data you provide in a common electronic format. As far as this is technically possible, you also have the right to demand the transmission of the data provided by you to another person responsible.
- Right of appeal
You have the right to complain to a regulator if you believe that your data is being processed unlawfully.
- Right of withdrawal
You have the right to revoke your consent to the processing of your data at any time. The lawfulness of data processing, which we have made up to your revocation, is not touched thereby.
- Contact point of data subjects’ rights
If you want to exercise your rights please contact via e-mail to firstname.lastname@example.org. In the case of requests for disclosure we request that you send us an official ID copy for the purpose of your identification.
10. Data security measures
We fully comply with all statutory data security measures.
11. Legal notice on links
Paul Putz & Partner Management Consultants GmbH constantly checks and updates the information on its website. Despite all care the data can have changed in the meantime. A liability or guarantee for the timeliness, accuracy and completeness of the information provided can therefore not be assumed. The same applies to all other websites referred to by hyperlink. The establishment of links to such websites is at your own risk. Paul Putz & Partner Management Consultants GmbH is not responsible for the content of websites reached via such links.
Furthermore, Paul Putz & Partner Management Consultants GmbH reserves the right to make changes or additions to the information provided.
12. Legal notice on the use of the content of our website
The content and structure of the Paul Putz & Partner Management Consultants GmbH website is protected by copyright. The reproduction of information or data, in particular the use of texts, parts of texts or images requires the prior consent of Paul Putz & Partner Management Consultants GmbH.
The use of content such as texts or images from this website for private or commercial purposes requires our express written permission. In the case of direct or indirect references to external Internet pages (“links”), we assume no liability whatsoever for the content there.
13. No Offer
No content of this Website constitutes an offer to buy or sell, an invitation to tender, investment advice or a recommendation to buy, sell or subscribe any financial instrument. It is of indicative and informative nature only and cannot be relied upon as the basis of any agreement with, or any obligation of Paul Putz & Partner Management Consultants GmbH, or any investment decision of the user of this Website. Any offer made by Paul Putz & Partner Management Consultants GmbH is always based exclusively on the relevant offering prospectus or, in case no prospectus is required, such other offering document explicitly declared to be binding by Paul Putz & Partner Management Consultants GmbH.
The information made available on this Website is of general nature only, cannot take into account any individual requirements, in particular in terms of yield, tax effects or risk profile, and cannot substitute individual advice. Users of this Website should consult their own advisers (in particular legal and tax advisers) to ensure that certain products, services or strategies meet their needs and expectations, and that they have fully understood the associated risks.
In any case, all information, materials and services made available on this Website are only intended for persons not subject to any legal restrictions in this regard. The users of this Website shall inform themselves about, and comply with any such restrictions.
14. Past performance is not a reliable indication of future developments
Any information, analysis or forecasts made available on this Website is based on knowledge and information and a market assessment as of the time it is made available. Paul Putz & Partner Management Consultants GmbH is not obliged to update or amend any information. Any applicable tax information is dependent on individual personal circumstances and may be subject to future changes.