Name and address of the person responsible
The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states as well as other provisions of data protection law is the Data Protection Officer:
EWG Vermögensverwaltung GmbH
Konstanzer Straße 10
I. General information on data processing
1.1 Scope of processing of personal data
We process the personal data of our users only to the extent necessary to provide a functioning website as well as our content and services. The processing of personal data of our users takes place regularly only with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory provisions.
1.2 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing personal data, Art. 6 Para. 1 lit. a EU Data Protection Basic Regulation (RGPD) serves as the legal basis. Art. 6 para. 1 lit. b EU Data Protection Basic Regulation serves as the legal basis for the processing of personal data required for the performance of a contract of which the data subject is the contracting party. 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 fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c RGPD serves as the legal basis. Art. 6 para. 1 lit. d RGPD serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data. If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f RGPD serves as the legal basis for the processing.
1.3 Data deletion and storage period
The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage no longer applies. In addition, the data may be stored if the European or national legislator has provided for this in Union regulations, laws or other provisions to which the person responsible is subject. The data shall also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.
II. Provision of the website and creation of log files
2.1 Description and scope of data processing
Each time you access our website, 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 the version used
(2) The user's operating system
(3) The User's Internet Service Provider
(4) The IP address of the user
(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 through our Website
The log files do not contain any IP addresses or other data that allow an assignment to a user. The data is also stored in the log files of our system. Not affected are the IP addresses of the user or other data that enable the assignment of the data to a user. These data are not stored together with other personal data of the user.
2.2 Legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f RGPD.
2.3 Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the IP address of the user must remain stored for the duration of the session.
2.4 Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data to provide the website, this is the case when the session in question has ended.
3.1 Description and scope of data processing
- Language settings
3.2 Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f RGPD.
3.3 Purpose of data processing
We need cookies for the following applications:
- Acceptance of language settings
- To simplify operation
- To improve the quality and content of our website.
The user data collected by technically necessary cookies are not used to create user profiles.
In these purposes, our legitimate interest lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f RGPD.
3.4 Duration of storage, objection and removal options
IV. Rights of the data subject
The following list includes all rights of the persons concerned under the RGPD. Rights which are not relevant for the own website do not have to be mentioned. In this respect, the list can be shortened if personal data is processed by you, you are the data subject within the meaning of the RGPD and you are entitled to the following rights vis-à-vis the person responsible:
4.1 Right to information
You can request confirmation from the person responsible as to whether personal data relating to you will be processed by us.
In the event of such processing, you may request the following information from the data controller:
(1) the purposes for which the personal data will be processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom the personal data relating to you has been or will be disclosed;
(4) the planned duration of the retention of the personal data relating to you or, if it is not possible to provide specific information in this regard, criteria for determining the retention period;
(5) the existence of a right to rectify or delete personal data concerning you, a right to limit the processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) all available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22 (1) and (4) RGPD and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.
You have the right to request information as to whether the personal data concerning you will be transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 RGPD in connection with the transfer.
4.2 Right to rectification
You have the right to have your personal data corrected and/or completed by the data controller if the personal data processed concerning you is inaccurate or incomplete. The data controller must carry out the rectification immediately.
4.3 Right to limitation of processing
Under the following conditions, you may request that the processing of your personal data be restricted:
(1) if you dispute the accuracy of the personal data concerning you for a period of time which allows the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse to erase the personal data and instead request that the use of the personal data be restricted;
(3) the controller no longer needs the personal data for the purposes of the processing, but you need them for the assertion, exercise or defence of legal claims, or
(4) if you have objected to the processing pursuant to Art. 21 para. 1 RGPD and it has not yet been established whether the legitimate reasons of the data controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data - apart from their storage may only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State. If the processing restriction has been limited in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4.4 Right to deletion
1) Cancellation obligation
You may request the data controller to delete the personal data concerning you immediately and the data controller is obliged to delete this data immediately if one of the following reasons applies:
(a) personal data relating to you are no longer necessary for the purposes for which they were collected or otherwise processed.
(b) You revoke the consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a RGPD and there is no other legal basis for the processing.
(c) You object to the processing pursuant to Art. 21 para. 1 RGPD and there are no overriding legitimate reasons for the processing or you object to the processing pursuant to Art. 21 para. 2 RGPD.
(d) The personal data concerning you have been processed unlawfully.
(e) The deletion of your personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
(f) The personal data relating to you have been collected in relation to information society services offered pursuant to Article 8(1) RGPD.
2) Information to third parties
If the person responsible has made the personal data concerning you public and is obliged to delete them in accordance with Art. 17, para. 1 RGPD, he shall, taking into account the available technology and the implementation costs, take appropriate measures, also of a technical nature, to inform the person responsible for data processing who is processing the personal data that you, as the person concerned, have requested the deletion of all links to this personal data or copies or replications of this personal data.
The right to deletion does not exist if the processing is necessary
(a) to exercise the right of freedom of expression and information;
(b) to fulfil a legal obligation which processing is subject to under the law of the Union or of the Member States to which the controller is subject or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 RGPD;
(d) for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 RGPD, insofar as the law referred to under section a) presumably makes the attainment of the objectives of such processing impossible or seriously impairs them, or
(e) to assert, exercise or defend legal claims.
4.5 Right to information
If you have exercised your right to rectify, cancel or limit the processing of your personal data against the controller, the latter is obliged to notify all recipients to whom the personal data concerning you have been disclosed of such rectification, cancellation or limitation, unless this proves impossible or involves a disproportionate effort. You have the right to be informed of such recipients by the data controller.
4.6 Right to data transferability
You have the right to receive the personal data concerning you that you have provided to the responsible person in a structured, common and machine-readable format. In addition, you have the right to communicate these data to another data controller without being hindered by the controller to whom the personal data was provided, provided that
(1) the processing is based on a consent pursuant to Art. 6 para. 1 lit. a RGPD or Art. 9 para. 2 lit. a RGPD or on a contract pursuant to Art. 6 para. 1 lit. b RGPD and
(2) the processing is carried out by automated means.
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this. The right to data transfer 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.
4.7 Right of objection
You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data on the basis of Art. 6 para. 1 lit. e or f RGPD; this also applies to profiling based on these provisions. The person responsible will no longer process the personal data concerning you unless he can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes. You have the possibility to exercise your right of objection through automated procedures using technical specifications in connection with the use of Information Society services, notwithstanding Directive 2002/58/EC.
4.8 Right to revoke declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of your consent does not affect the legality of the processing carried out on the basis of your consent until you revoke it.
4.9. Automated decision in individual cases including profiling
You have the right not to be subject to any decision based solely on automated processing, including profiling, that has any legal effect on you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the person responsible,
(2) is authorised by legislation of the Union or of the Member States to which the person responsible is subject and contains appropriate measures to safeguard your rights and freedoms and your legitimate interests or
(3) with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 RGPD unless Art. 9 para. 2 lit. a or g RGPD applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (2), the person responsible shall take appropriate measures to protect the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the person responsible, to state his own position and to challenge the decision.
4.10. Right to appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is in breach of the RGPD. The supervisory authority with which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 RGPD.