initiation
With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). ).
The terms used are not gender specific.
As of April 10, 2020
Table of Contents
- initiation
- Responsible
- Overview of processing
- Relevant legal bases
- Safety measures
- Transfer and Disclosure of Personal Data
- Data processing in third countries
- Use of cookies
- Blogs and publication media
- contact
- Provision of the online offer and web hosting
- Affiliate Programs and Affiliate Links
- deletion of data
- Change and update of the privacy policy
- Rights of data subjects
- definitions of terms
Responsible
Philip Haarman
Zamboninistr. 25
80638 Munich
Germany
E-mail address: philip@crowd-investor.eu
imprint: https://www.crowd-investor.eu/impressum/
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data (e.g. names, addresses)
- Content data (e.g. text input, photographs, videos)
- Contact information (e.g. email, phone numbers)
- Meta/communication data (e.g. device information, IP addresses)
- Usage data (e.g. websites visited, interest in content, access times)
- Contract data (e.g. subject matter, term, customer category)
Categories of data subjects
- communication partner
- Users (e.g. website visitors, users of online services)
purposes of processing
- Affiliate Tracking
- Feedback (e.g. collecting feedback via online form)
- Contact Requests and Communication
- Safety measures
- Contractual Benefits and Service
- Management and response to inquiries
Relevant legal bases
In the following we inform you about the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.
- Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures that are taken at the request of the data subject.
- Protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR) – Processing is necessary to protect vital interests of the data subject or another natural person.
- Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR) – Processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Safety measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transfer and Disclosure of Personal Data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or pass the data in third countries with a recognized level of data protection, which include US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligations so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files containing data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was viewed. The term “cookies” also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Persistent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users, which are used to measure reach or for marketing purposes, can be stored in such a cookie.
- First party cookies: First-party cookies are set by us.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or strictly necessary) cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
- Statistics, marketing and personalization cookies: Cookies are also generally used to measure range and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to show users, for example, content that corresponds to their potential interests. This procedure is also referred to as "tracking", ie tracking the potential interests of users. . If we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or when obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (which can also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be raised using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process or have data processed within the framework of the use of cookies, we ask the user to give their consent, which can be revoked at any time. Before the consent has not been given, cookies that are required for the operation of our online offer will be used. They are used on the basis of our interest and the interest of the user in the expected functionality of our online offer.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected people: Users (e.g. website visitors, users of online services).
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). The data of the readers are processed for the purposes of the publication medium only insofar as it is necessary for its presentation and the communication between authors and readers or for reasons of security. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
Comments and Posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is for our security if someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for the duration of the survey and to use cookies to avoid multiple votes.
The personal information provided in the comments and posts, any contact and website information as well as the content will be stored by us permanently until the user objects.
comment subscriptions: The follow-up comments can be subscribed to by users with their consent. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purpose of proving the user's consent, we store the time of registration along with the IP address of the user and delete this information if the user unsubscribes from the subscription.
You can cancel receiving our subscription at any time, ie revoke your consent. We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information , IP addresses).
- Affected people: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual services and services, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries, contact requests and communication.
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a GDPR), protection of vital interests (Art. 6 Para. 1 S. 1 lit. d. GDPR).
contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the details of the requesting person will be processed to the extent that this is necessary to answer the contact request and any requested measures.
The answering of contact inquiries within the framework of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos)
- Affected people: communication partner
- Purposes of processing: Contact Requests and Communication
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR)
Provision of the online offer and web hosting
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Email delivery and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail dispatch (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot accept any responsibility for the transmission path of the e-mails between the sender and receipt on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.
The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability.
- Types of data processed: Content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
- Affected people: Users (e.g. website visitors, users of online services)
- Legal bases: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR)
Affiliate Programs and Affiliate Links
We include so-called affiliate links or other references (which may include discount codes, for example) to the offers and services of third-party providers (collectively referred to as “affiliate links”) in our online offering. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").
In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to know that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves solely the purpose of the commission statement and is canceled as soon as it is no longer required for the purpose.
For the purposes of the aforementioned assignment of the affiliate links, the affiliate links can be supplemented with certain values that are part of the link or can be stored in some other way, e.g. in a cookie. The values can include, in particular, the source website (referrer), the time, an online ID of the operator of the website on which the affiliate link was located, an online ID of the respective offer, the type of link used, the type of offer and an online identifier of the user.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Furthermore, their use can be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of data processed: Contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses)
- Affected people: Users (e.g. website visitors, users of online services)
- Purposes of processing: Affiliate Tracking
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR)
deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).
If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the context of the individual data protection information in this data protection declaration.
Change and update of the privacy policy
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which result in particular from Articles 15 to 18 and 21 GDPR:
- 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, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
- Right of withdrawal for consent: You have the right to revoke your consent at any time.
- Right of providing information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted immediately, or alternatively to request a restriction of the processing of the data in accordance with the legal requirements.
- Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request its transmission to another person responsible.
- Complaint to supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the member state of your usual place of residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR violates.
definitions of terms
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.
- Affiliate Tracking: As part of affiliate tracking, links that the linking websites use to direct users to websites that offer products or other services are logged. The operators of the linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. buy goods or use services). To do this, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for affiliate links to work that they are supplemented with certain values that become part of the link or are stored in some other way, e.g. in a cookie. The values include in particular the source website (referrer), the time, an online ID of the operator of the website on which the affiliate link was located, an online ID of the respective offer, an online ID of the user and tracking-specific values , such as advertising media ID, partner ID and categorizations.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Responsible: The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
- Processing: "Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.