Data privacy

Information on data privacy

Data Privacy Statement

Please find below our statement on the processing of personal data by our company in accordance with the legal requirements, especially with the EU General Data Protection Regulation (GDPR – available athttp://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679).

Contents:
I. General information
1. Definition of main terms
2. Scope of validity
3. Controller
4. Data protection officer

II. Itemisation of data processing operations
1. General information about the data processing operations
2. Accessing our services
3. Contact form
4. Tracking

III. Rights of data subjects
1. Right to object
2. Right of access
3. Right to rectification
4. Right to erasure (“right to be forgotten”)
5. Right to restriction of processing
6. Right to data portability
7. Right to withdraw consent
8. Right to lodge a complaint

I. General information
This section of the privacy statement contains information on the scope of validity, the person responsible for data processing, the data protec-tion officer and data security. It also begins with a list of definitions of important terms used in the data privacy statement.

1. Definition of main terms
Browser: Computer program used to display websites (e.g., Chrome, Firefox, Safari)

Cookies: Text files which the web server places on the user’s computer by means of the browser which is used. The stored cookie information may con-tain both an identifier (cookie ID) for recognition purposes and content data, such as login status or information about websites visited. The browser sends the cookie information back to the web server with each new request upon subsequent repeat visits to these sites. Most browsers accept cookies automatically. Cookies can be managed using the browser functions (usually under “Options” or “Settings”). The storage of cookies may be disabled in this way or it may be made dependent on the user’s approval in any given case or otherwise restricted. Cookies may also be deleted at any time.

Third countries: Countries outside the European Union (EU)

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679

Personal data: Any information relating to an identified or identifiable natural person. 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 or to one or more fac-tors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Profiling: Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Services: Our offers to which this data privacy statement applies (cf. Scope of validity).

Tracking: The collection of data and their evaluation regarding the behaviour of visitors in response to our services.

Tracking technologies: Actions can be tracked either via the activity records (log files) stored on our web servers or by collecting data from end devic-es via pixels, cookies or similar tracking technologies.

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissem-ination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pixel: Pixels are also called tracking pixels, web beacons or web bugs. These are small, invisible graphics in HTML emails or on websites. When a doc-ument is opened, this small image is downloaded from a server on the Internet and the download is registered there. This allows the operator of the server to see if and when an email has been opened or a website has been visited. This function is usually carried out by calling up a small program (Ja-vaScript). Certain types of information can be detected on your computer system in this way and shared, such as the content of cookies, the time and date of the visit, and a description of the page on which the tracking pixel is located.

2. Scope of validity
This data privacy statement applies to our website www.burdaprincipalinvestments.com, hereinafter referred to as “services”.

3. Controller
The following party is responsible for the processing of data in relation to the services, i.e., this is the person who determines the purposes and means of processing personal data:

Burda Principal Investments GmbH & Co. KG
Arabellastraße 23
81925 München
Germany
Email: investments@burda.com

4. Data protection officer
Our data protection officer can be contacted under the data given in paragraph 3., for the attention of the data privacy department or via investments@burda.com.

II. Itemisation of data processing operations
This section of the data privacy statement contains detailed information about the processing of personal data in the context of our services. The information is subdivided for greater clarity into certain functions in connection with our services. In case of the normal use of the services, dif-ferent functions and therefore also different processing operations can be implemented consecutively or simultaneously.

1. General information about the data processing operations
The following applies to all the processing operations listed below, unless stated otherwise:

a. No obligation to provide personal data & consequences of failure to provide such data
The provision of personal data is not required by law or contract, and you are under no obligation to provide any data. We will inform you during the da-ta entry process when personal information needs to be provided for the relevant service (e.g., by indicating “mandatory fields”). In cases where the provision of data is required, the consequence of not providing data will be that the service in question cannot be provided. Otherwise, failure to provide data may result in our inability to provide our services in the same form and quality.

b. Transfer of personal data to third countries
When we send data to third countries, i.e., countries outside the European Union, the data are then transmitted strictly in compliance with the statutory conditions of admissibility.
If the transmission of the data to a third country does not serve the purpose of fulfilling our contract with you, if we do not have your consent, if the transmission is not required for the establishment, exercise or defence of legal claims, and if no other exemption applies under Art. 49 GDPR, we will only transmit your data to a third country if in possession of an adequacy decision pursuant to Art. 45 GDPR or appropriate safeguards under Art. 46 GDPR.
One of these adequacy decisions is the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the “EU-US Privacy Shield” for the USA. The level of data protection is generally considered to be appropriate according to Art. 45 GDPR for transfers to companies which are certified under the EU-US Privacy Shield.
Alternatively or additionally, safeguards under Art. 46 subs. 2 c) GDPR through the conclusion of the EU standard data protection clauses adopted by the European Commission with the receiving body provide appropriate safeguards and an adequate level of data protection. Copies of the standard EU data protection clauses are available on the website of the European Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

c. Hosting at external service providers
Our data processing work is carried out to a large extent with the involvement of hosting service providers who provide us with storage space and pro-cessing capacities at their data centres and who also process personal data on our behalf according to our instructions. It may be the case that person-al data are transmitted to hosting service providers in respect of all of the functions listed below. These service providers process data either exclusive-ly in the EU or subject to guaranteed levels of data protection which we have put in place based on the standard EU data protection clauses (cf. sub-section c.).

d. Transmission to government authorities
We send personal information to government authorities (including law enforcement agencies) when required to fulfil a legal obligation to which we are subject (legal basis: Art. 6, subs. 1 c), GDPR) or when it is necessary for the assertion, exercise or defence of legal claims (legal basis: Art. 6, subs. 1 f), GDPR).

e. Period of storage
The time specified in the “period of storage” paragraph indicates how long we use the data for the purposes in any given case. At the end of this peri-od, the data will no longer be processed by us but will be deleted at regular intervals, unless continued processing and storage are required by law (in particular, because it is necessary to fulfil a legal obligation or for the establishment, exercise or defence of legal claims) or unless you grant us extended consent.

f. Data categories
The category names listed below are used for specific types of data in the following sections:

o Personal data: Title, salutation/gender, forename, surname
o Contact data: Telephone number(s), fax number(s), email address(es)
o Access data: Date and time of visit to our service; the page from which the system accessed our site; pages visited during the session; ses-sion identification data (session ID), as well as the following information relating to the computer system accessing the service: Internet Proto-col address used (IP address), browser type, browser version, device type, operating system and similar technical information.

2. Accessing our services
The passages below set out how your personal data are processed when you access our services (e.g., loading and viewing the website).

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interest, where applicable Storage period
Access data Establishing connection, presenting contents of the service, detecting attacks on our site due to unusual activities, fault diagnosis Art. 6, subs. 1 f), GDPR Proper functioning of services, security of data and business processes, prevention of misuse, prevention of damage through interference in information systems 4 weeks

 

 

b. Recipients of personal data

Recipient category Data concerned Legal basis Legitimate interests, where applicable
IT security service providers Access data Art. 6, subs. 1 f), GDPR Prevention of attacks through exploitation of security gaps / vulnerabilities


3. Contact form

The tables below show how your personal data are processed when you use our contact form.

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interests, where applicable Period of storage
Personal master data, contact data, contents of enquiries Processing of enquiries Art. 6, subs. 1 b), f), Manage deal flow, sustain conversation with market participants 2 years


4. Tracking

The passages below explain how your personal data are processed with the help of tracking technologies to analyse and optimise our services and to serve promotional purposes.
The explanation of the tracking methods also includes information on how to prevent or object to the processing of data.
Please note that this “opt-out” request, i.e., denial of consent to processing, is usually stored via cookies. If you use our services on a new end device or in a different browser, or if you have deleted the cookies set by your browser, you will need to reconfirm the refusal of consent.
The tracking methods presented here will only process personal data in pseudonymous form . No connection is made with a specific, identified natural person, i.e., the data are not merged with information which would reveal the identity of the person behind the pseudonym.

a. Tracking for the analysis and optimisation of our services and their use

(1) Purpose of processing
The analysis of user behaviour by means of tracking helps us to check the effectiveness of our services, to improve and adapt them to the needs of the users, and to correct errors. It also allows us to produce statistics on the use of our services (reach, intensity of use, surfing habits of users) – on the basis of uniform standard procedures – and thereby to obtain comparable figures across the market.

(2) Legal basis of processing
In cases where we provide services under a contract, the tracking and the associated analysis of user behaviour are carried out in order to fulfil our con-tractual obligations. The legal basis for this processing of personal data is Art. 6, subs. 1 b), GDPR. The evaluation of information obtained through tracking is necessary in order to optimise the provision of services according to the contractual purpose and to ensure the greatest possible benefit for you.
Otherwise, i.e., in cases where services are not connected with a contract, the legal basis for this processing of personal data is Art. 6, subs. 1 f), GDPR. We hereby pursue the legitimate interest in providing attractive services as efficiently as possible on the basis of the information gained through tracking and marketing them in the best possible way.

(3) Explanation of individual tracking methods

Name of service Mode of operation Option of preventing processing (opt-out) Data transfer to third country? Adequacy decision, where applicable (Art. 45 GDPR) Appropriate guarantees, where applicable (Art. 46 GDPR)
Matomo (formerliy PIWIK) Matomo is a service of InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand.

Matomo collects information on user behaviour in order to improve the usability of the website

Processing of personal data

This website uses the service Matomo with the add-on „AnonymizeIP“, through which IP addresses are shortened in order to eliminate direct reference to a person.

Please use the form under III. (9) at the bottom of this page to opt-out No Not necessary Not necessary

III. Rights of data subjects
1. Right to object
If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data con-cerning you for such marketing with future effect, which includes profiling to the extent that it is related to such direct marketing.
You also have the right, at any time with future effect and for reasons relating to your particular situation, to object to the processing of personal data concerning you which is based on Art. 6, subs. 1 e) or f), GDPR, including profiling based on these provisions.
The right to object may be exercised free of charge. In order to be able to process your request faster, please reach us using the contact information provided in paragraph I.3., e.g . via email to: investments@burda.com.

2. Right of access
You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the other information listed in Art. 15 GDPR .

3. Right to rectification
You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay (Art. 16 GDPR). Taking into ac-count the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplemen-tary statement.

4. Right to erasure (“right to be forgotten”)
You have the right to obtain from us the erasure of personal data concerning you without undue delay if one of the reasons listed in Art. 17, subs. 1, GDPR is applicable and the processing operations are not required for one of the purposes approved in Art. 17, subs. 3, GDPR.

5. Right to restriction of processing
You are entitled to obtain from us the restriction of the processing of personal data if one of the conditions laid down in Art. 18, subs. 1 a) to d), GDPR is met.

6. Right to data portability
Under the conditions set out in Art. 20, subs. 1, GDPR, you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance on our part. In ex-ercising your right to data portability, you have the right to have the personal data transmitted directly by us to another controller where technically fea-sible.

7. Right to withdraw consent
If the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

8. Right to lodge a complaint
You have the right to lodge a complaint with the supervisory authority responsible for our company. The supervisory authority responsible for our com-pany is:
Landesamt für Datenschutzaufsicht, Promenade 27 (Schloss), 91522 Ansbach, http://www.lda.bayern.de

9. Option of preventing processing