Privacy policy

In accordance with the legal requirements of data protection law (in particular the Federal Data Protection Act (BDSG) as amended and the European Data Protection Regulation (DS-GVO)), we would like to inform you about the type, scope and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and LinkedIn profiles.

With regard to the definition of terms such as “personal data” or “processing”, we refer to Art. 4 DS-GVO.

Name and contact details of the person responsible

Our responsible person(s) (hereinafter referred to as “Responsible Person”) within the meaning of Art. 4 No. 7 DS-GVO is

Wydler Asset Management (Germany) GmbH
Viktoriastr. 3 b
86150, Augsburg, Germany
e-mail: info@wydlerinvest.de

Rights of the person concerned

You have the following rights towards us as a data subject according to the DS-GVO (shortened presentation for reasons of transparency)

  1. right to information, Art.15 DS-GVO
  2. right of correction, Art.16 DS-GVO
  3. right of deletion, Art.17 DS-GVO
  4. right of restriction, Art.18 DS-GVO
  5. right to data transferability, Art.20 DS-GVO
  6. right to object to the processing of your data in accordance with Art.21 DS-GVO and to revoke any consent given in accordance with Art.7 Par.3 DS-GVO

You have the following rights towards us as a data subject according to the DS-GVO

Insofar as the processing is based on your consent in accordance with Art. 6 para. 1 sentence 1 lit. a), Art. 7 DS-GVO, you have the right to revoke your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

Insofar as we base the processing of your personal data on the weighing of interests in accordance with Art. 6 Para. 1 S. 1 lit. f) DS-GVO, you may object to the processing in accordance with Art. 21 DS-GVO. This is the case if the processing is in particular not necessary for the fulfilment of a contract with you, which we will describe in the following description of the functions. In the event of such an objection, we request that you explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the facts of the case and will either stop or adapt the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing.

You can object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can exercise the right of objection free of charge. You can inform us about your objection to the processing of your personal data under the following contact details:

Wydler Asset Management (Germany) GmbH
Viktoriastr. 3 b
86150, Augsburg, Germany
e-mail address: infowydlerinvest.de

  1. right of complaint

In accordance with Art 77 DS-GVO, you have the right to complain to a data protection supervisory authority about the processing of your personal data. As a rule, you can contact the supervisory authority for this purpose, in particular in the member state where you reside, your place of work or the location of the suspected infringement.

The data protection supervisory authority responsible for us is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach

Phone: +49 (0) 981 180093-0
Fax: +49 (0) 981 180093-800
E-mail: poststelle@lds.bayern.de

 

Data types, purposes of processing and categories of data subjects

  1. types of data processed

When you visit our website, the following types of personal data are processed:

-- Usage data (access times, websites visited
-- inventory data (name, address
-- Contact information (phone number, e-mail, fax
-- Payment data (bank data, account data, payment history)
-- Contract data (subject of the contract, duration)
-- Content data (text input, videos, photos)
-- Communication data (IP address)

  1. the purposes of the processing pursuant to Art. 13 (1) c) DS-GVO

We process this data for the following purposes:

-- Processing of contracts,
-- Optimize website technically and economically,
-- Provide easy access to the website,
-- Fulfillment of contractual obligations,
-- Contact in case of legal complaints by third parties,
-- Fulfillment of legal storage obligations,
-- Optimization and statistical evaluation of our services,
-- Support commercial use of the website,
-- Improve user experience,

-- Make the website user-friendly,
-- Economic operation of advertising and website, marketing / sales / advertising,
-- Creation of statistics,
-- Determine copy probability of texts,
-- Avoidance of SPAM and abuse,
-- Customer service and customer care,
-- handle contact requests,
-- Provide websites with features and content,
-- Safety measures,
-- Uninterrupted, secure operation of our website

We will inform you about the concretely processed data separately for the individual processing activities.

Legal basis of the processing of personal data

Your personal data will only be processed if one of the legal bases mentioned in Art.6 para.1 DSGVO is present:

  1. according to art. 6 para. 1 sentence 1 lit. a) DS-GVO, on the basis of your consent
  2. in accordance with Art. 6 (1) sentence 1 letter b) DS-GVO, if the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures
  3. in accordance with Art. 6 para. 1 sentence 1 lit. c) DS-GVO, if the processing is necessary to fulfil a legal obligation to which we are subject (e.g. statutory storage obligations)
  4. in accordance with Article 6 (1) sentence 1 lit. d) DS-GVO, to protect the vital interests of the person concerned or of another natural person
  5. in accordance with Art. 6 para. 1 sentence 1 letter f) DS-GVO, if the processing is necessary to protect our interests or the legitimate interests of a third party and in this respect your interests or fundamental rights and freedoms do not prevail,

We will inform you separately about the relevant legal basis for the individual processing activities.

Passing on of personal data to third parties and contract processors

We will only pass on your personal data to third parties on one of the aforementioned legal bases of Art.6 DS-GVO. This is the case when data is passed on to online payment providers for the purpose of fulfilling a contract, in the event of a court order or due to a legal obligation to surrender the data for the purpose of criminal prosecution, to avert danger or to enforce intellectual property rights.

We also use contract processors (external service providers) for web hosting of our websites and databases to process your data. If data is passed on to the processors within the framework of an agreement for order processing, this is always done on the basis of the regulations in Art. 28 DS-GVO. We select our processors carefully, check them regularly and have been granted the right to issue instructions regarding the data. In addition, the processors must have taken suitable technical and organizational measures and comply with the data protection regulations according to BDSG n.F. and DS-GVO

 

Data transfer to third countries

With the adoption of the European Data Protection Basic Regulation (DS-GVO), a uniform basis for data protection in Europe was created. Your data is therefore processed primarily by companies to which the DS-GVO applies. If, however, processing is carried out by services of third parties outside the European Union or the European Economic Area, they meet the special requirements of Art. 44 ff. DS-GVO. This means that the processing is carried out on the basis of special guarantees, such as the EU Commission’s officially recognized determination of a level of data protection corresponding to that of the EU or compliance with officially recognized special contractual obligations, the so-called “standard contractual clauses”.

Deletion of data and storage duration

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as the purpose for which it was stored ceases to apply, unless further storage is required for evidential purposes or if this is contrary to the statutory storage obligations. This includes, for example, commercial storage obligations for business letters according to § 257 para. 1 HGB (6 years) and tax storage obligations according to § 147 para. 1 AO of receipts (10 years). If the prescribed retention period expires and no use of the data for a specific purpose is required, your data will be blocked or deleted. We will provide further special information on the deletion of your data separately for each individual processing activity.

 

Existence of an automated decision making process

We do not use automatic decision making or profiling.

Provision of our website and creation of log files

If you use our website for informational purposes only (i.e. no registration or other transmission of information), we only collect the personal data that your browser sends to our server. If you wish to view our website, we collect the following data:

-- IP address;
-- Internet service provider of the user;
-- date and time of access;
-- browser type;
-- language and browser version;
-- content of the retrieval;
-- time zone;
-- access status/HTTP status code;
-- amount of data;
-- Websites from which the request comes;
-- operating system.

This data will not be stored together with other personal data about you.

  1. these data serve the purpose of the user-friendly, functional and secure delivery of our website to you with functions and contents as well as their optimization and statistical evaluation.

3) The legal basis for this is our legitimate interest in data processing in accordance with Art. 6 Para. 1 S.1 lit. f) DS-GVO, which is also contained in the above-mentioned purposes.

For security reasons, we store this data in server log files for a storage period of 14 months. After this period has elapsed, they are automatically deleted, unless we require their storage for evidence purposes in the event of attacks on the server infrastructure or other legal violations.

Cookies

  1. we use so-called cookies when you visit our website. Cookies are small text files that your internet browser places and saves on your computer. When you visit our website again, these cookies provide information to automatically recognize you. The information obtained in this way serves the purpose of optimising our web offers both technically and economically and of enabling you to access our website more easily and securely. When you call up our website, we will inform you about the use of cookies for the aforementioned purposes and how you can object to or prevent their storage (“opt-out”) by referring to our data protection declaration. Our website uses session cookies, persistent cookies and third-party cookies:

 

-- Session cookies: We use so-called cookies to recognize multiple use of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information obtained in this way is used to optimize our offers and make it easier for you to access our site. When you close the browser or log out, the session cookies are deleted.

-- Persistent cookies: These are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.

-- Third-party cookies: You can configure your browser settings according to your preferences, e.g. you can refuse to accept third-party cookies or all cookies. However, please note that if you do so, you may not be able to use all the features of this website. Please read more about these cookies in the respective third-party privacy statements.

The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. b) DS-GVO if the cookies are set for the initiation of a contract, e.g. in the case of orders, and otherwise we have a legitimate interest in the effective functionality of the website, so that in this case the legal basis is Art. 6 para. 1 sentence 1 lit. f) DS-GVO.

  1. objection and “opt-out”: You can object to the processing of your data by cookie technologies at any time. We would like to point out that this may result in a functional limitation of our offers. You can generally prevent cookies from being stored on your hard drive by selecting “do not accept cookies” in your browser settings. You can object to the use of cookies from third parties for advertising purposes by means of a so-called “opt-out” via this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/).

4th revocation: If you have given your consent to data processing by cookie technologies, you can revoke it at any time by deselecting (opt-out) in the cookie management tool. You can find more detailed information on those requiring consent under the relevant points of the data protection declaration.

 

Processing of contracts

  1. we process inventory data (company, title/academic degree, names and addresses as well as contact data of users, e-mail), contract data (services used, names of contact persons) and payment data (bank details, payment history) for the purpose of fulfilling our contractual obligations (knowing who is the contractual partner; justification, content and processing of the contract; checking the plausibility of the data) and services (contacting customer service) in accordance with Art. 6 Para. 1 S. 1 lit b) DS-GVO. The entries marked as mandatory in online forms are required for the conclusion of the contract.
  2. this data will not be passed on to third parties unless it is necessary to pursue our claims (e.g. transfer to a lawyer for collection), to fulfill the contract (e.g. transfer of data to payment providers) or if there is a legal obligation to do so in accordance with Art. 6 para. 1 sentence 1 lit. c) DS-GVO.
  3. the data will be deleted as soon as they are no longer necessary for the purpose of their collection. This is the case for the inventory and contract data when the data is no longer necessary for the execution of the contract and no more claims can be asserted under the contract because they are time-barred (warranty: two years / standard limitation period: three years). We are obliged by commercial and tax law to store your address, payment and order data for a period of ten years. However, if the contract is terminated after three years, we will restrict processing, i.e. your data will only be used to comply with legal obligations. Details in the user account remain until it is deleted.

Advertising

If you are an existing customer, we also process the inventory data you provide to inform you about other interesting products from our portfolio or to send you e-mails with technical information. The legal basis for this is our legitimate interest according to Art.6 para.1 lit.f DS-GVO.

You can object to this processing at any time.

 

Contact via contact form / e-mail / fax / post

  1. when contacting us via contact form, fax, mail or e-mail, your personal information and data will be processed for the purpose of processing the contact request.
  2. the legal basis for the processing of the data is Art. 6 para. 1 p. 1 lit. a) DS-GVO if you have given your consent. The legal basis for the processing of data transmitted in the course of a contact inquiry or e-mail, letter or fax is Art. 6 Paragraph 1 S. 1 lit. f) DS-GVO. We have a legitimate interest in the processing and storage of the data in order to be able to answer users’ inquiries, to secure evidence for liability reasons and, if necessary, to comply with its statutory obligations to retain business letters. If the purpose of the contact is the conclusion of a contract, the legal basis for processing is Art. 6 para. 1 sentence 1 lit. b) DS-GVO.
  3. we may store your details and contact request in our customer relationship management system (“CRM system”) or a comparable system.
  4. the data will be deleted as soon as they are no longer required for the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with you has ended. The conversation ends when it is clear from the circumstances that the matter in question has been finally clarified. Inquiries from users who have an account or a contract with us will be stored for a period of two years after termination of the contract. In the case of legal archiving obligations, deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) retention obligation.
  5. you have the possibility at any time to revoke your consent pursuant to Art. 6 para. 1 sentence 1 lit. a) DS-GVO to the processing of personal data. If you contact us by e-mail, you can object to the storage of your personal data at any time.

 

Contact by telephone

  1. when contacting us by phone, your phone number will be processed and temporarily stored or displayed in the RAM / cache of the phone device / display for the purpose of processing the contact request and its handling. The storage is done for liability and security reasons to be able to prove the call and for economic reasons to enable a call back. In case of unauthorized advertising calls, we block the phone numbers.
  2. the legal basis for the processing of the telephone number is Art. 6 para. 1 p. 1 lit. f) DS-GVO. If the aim of the contact is to conclude a contract, the additional legal basis for processing is Art. 6 (1) lit. b) DS-GVO.
  3. the device cache stores the calls for days and successively overwrites or deletes old data; when the device is disposed of, all data is deleted and the memory destroyed if necessary. Blocked phone numbers are checked annually for the necessity of blocking.
  4. you can prevent the display of the phone number by calling with suppressed phone number.

Google Analytics

If you have given your consent, we use “Google Analytics”, a web analysis service of Google LLC.  The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

 

Scope of the processing

Google Analytics uses cookies that enable an analysis of your use of our website. The information collected by means of the cookies about your use of this website is usually transferred to a Google server in the USA and stored there.

We use the function User-ID. The User ID enables us to assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and to analyze user behavior across devices.

We use the function ‘anonymizeIP’ (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP address will be shortened by Google within member states of the European Union or in other states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other data from Google.

During your website visit the following data is recorded:

-- the pages you call up, your “click path

-- Achievement of “website goals” (conversions, e.g. newsletter registrations, downloads, purchases)

-- Your user behavior (for example clicks, dwell time, bounce rates)

-- Your approximate location (region)

-- Your IP address (in abbreviated form)

-- technical information about your browser and the end devices you use (e.g. language settings, screen resolution)

-- Your internet provider

-- the referrer URL (via which website/advertising medium you came to this website)

Purposes of processing

On behalf of the operator of this website, Google will use this information to evaluate your use of the website and to compile reports on website activities. The reports provided by Google Analytics serve to analyze the performance of our website and the success of our marketing campaigns.

Recipient

The recipient of the data is

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

As a contract processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.

Transfer to third countries

A transfer of data to the USA cannot be excluded.

Storage period

The data sent by us and linked to cookies is automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by

  1. do not give your consent to the setting of the cookie or
  2. Download and install the browser add-on to disable Google Analytics HERE.

You can also prevent the storage of cookies by setting your browser software accordingly. However, if you configure your browser to refuse all cookies, this may limit the functionality of this and other websites.

Legal basis and right of withdrawal

for this data processing is your consent, Art.6 para.1 S.1 lit. a DSGVO. You can withdraw your consent at any time with effect for the future by calling up the cookie settings and changing your selection there.

Further information on the terms of use of Google Analytics and on data protection at Google can be found at https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.

 

Google ReCAPTCHA

  1. we have integrated on our website the anti-spam function “reCAPTCHA” from “Google” (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). By using “reCAPTCHA” in our forms, we can determine whether the input was made by a natural person (humans) or abusively by machine and automated processing (robots). When using the service, your IP address and any other data required for this purpose may be transmitted to Google servers in the USA.

The purpose of processing this data is to avoid spam and misuse and our economic interest in optimizing our website.

  1. the legal basis for this is our legitimate interest in the above-mentioned purposes in data processing in accordance with Art. 6 Para. 1 S.1 lit. f) DS-GVO.
  2. you can find further information about Google ReCAPTCHA at https://www.google.com/recaptcha/ and in the Google privacy policy at https://policies.google.com/privacy.

Data security

In order to protect all personal data transmitted to us and to ensure that the data protection regulations are observed by us and our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted in encrypted form via a secure SSL connection.

 

Status of the privacy policy: 18.11.2020