This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Family Trust Investor FTI GmbH
Maximilian Street 52
TELEPHONE: +49 89 2154 730 – 0
FAX: +49 89 2154 730 – 99
Sales tax identification number: DE297086201
Registered office of the company: Munich
Commercial register: Munich Local Court, HRB 214276
Managing directors: Carsten Abdel Hadi, Andreas Augustin, Tobias Fuhrmann, Florian Schepp
Competent supervisory authority: Family Trust Investor FTI GmbH, as an external capital management company, is subject to the supervision of the Federal Financial Supervisory Authority, Marie-Curie-Straße 24-28, D-60439 Frankfurt am Main.
FTSA Beteiligungs GmbH
Sales tax identification number: DE303716570
Registered office of the company: Munich
Commercial register: Munich Local Court, HRB 220467
Managing directors: Andreas Augustin, Florian Schepp
– Inventory data (e.g., personal master data, names or addresses)
– Contact data (e.g., email, phone numbers)
– Content data (e.g., text input, photographs, videos)
– Usage data (e.g., web pages visited, interest in content, access times)
– Meta/communication data (e.g., device information, IP addresses)
Visitors and users of the online offer (hereinafter, we also refer to the data subjects collectively as “users”).
– Provision of the online offer, its functions and content
– Responding to contact requests and communicating with users
– Security measures
– Reach measurement/marketing
“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 reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
“Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. For users from the area of application of the Basic Data Protection Regulation (DSGVO), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the data protection declaration: The legal basis for obtaining consent is Art. 6 (1) lit. a and Art. 7 DSGVO; the legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 (1) lit. b DSGVO; the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c DSGVO; in the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 para. 1 lit. d DSGVO serves as the legal basis. The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO. The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO. The processing of data for purposes other than those for which they were collected is determined by the requirements of Art. 6 (4) DSGVO. The processing of special categories of data (according to Art. 9 (1) DSGVO) is determined according to the requirements of Art. 9 (2) DSGVO.
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 nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk. The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis that complies with the legal requirements.
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure, or transfer of data to other persons or companies, this will only occur if it is done for the fulfillment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the legal requirements are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations.
You have the right to obtain confirmation as to whether or not data concerning you is being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the law. You have the right, in accordance with. the legal requirements, to request that the data concerning you be completed or that incorrect data concerning you be corrected. You have the right, in accordance. with the legal requirements, to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data. You have the right to demand that the data concerning you that you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other persons responsible. You also have the right, in accordance with the law, to lodge a complaint with the competent supervisory authority.
You have the right to revoke any consent you have given with effect for the future.
You may object to the future processing of data relating to you at any time in accordance with the legal requirements. The objection can be made in particular against processing for direct advertising purposes.
Cookies” are small files that are stored on users’ computers. Various data can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
We ask you to inform yourself regularly about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
We process applicant data only for the purpose of and within the scope of the application procedure in accordance with legal requirements. Applicant data is processed for the fulfillment of our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 (1) lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).
The application procedure requires applicants to provide us with applicant data. The necessary applicant data are marked, if we offer an online form, otherwise result from the job descriptions and basically include the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, resume and the certificates. In addition, applicants may voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are voluntarily communicated within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a DSGVO (e.g. health data, if this is necessary for the exercise of the profession).
If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using an online form or sending by post. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post.
In the event of a successful application, the data provided by the applicants may be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified withdrawal by the applicants, the deletion will take place after the expiry of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.
As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 Para. 1 lit. a. and Art. 7 DSGVO. The application documents in the talent pool will be processed solely in the context of future job advertisements and employee searches and will be destroyed at the latest after the expiry of the period. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future and declare their objection within the meaning of Art. 21 DSGVO.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user will be used to process the contact request and its handling pursuant to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed… The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization. We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter is carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other 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 the storage of the registration and confirmation time, as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Registration data: To register for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. DSGVO in conjunction with. § Section 7 (3) UWG.
The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users and furthermore allows us to prove consent.
Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
The newsletter is sent by means of the dispatch service provider rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg i.Br., Germany. You can view the data protection provisions of the dispatch service provider here: https://www.rapidmail.de/datenschutzbestimmungen. The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and a contract processing agreement pursuant to Art. 28 para. 3 p. 1 DSGVO. The dispatch service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider 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. Unfortunately, a separate revocation of the performance measurement is not possible, in which case the entire newsletter subscription must be cancelled.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Users’ personal data is deleted or anonymized after 14 months.
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services there.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to U.S. providers that are certified under the Privacy Shield, we point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
We use within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.