Data protection declaration

  1. General Information and Principles of Data Processing

    We are very pleased that you visit our Investors Platform. Protection of your privacy and of your personal data in the course of using our platform is important to us.

    Personal data means, according to Art. 4 No. 1 GDPR, any information relating to an identified or identifiable natural person. That includes, for example, your first and family names, your address, your telephone number, your e-mail address but also your IP address. Data from which no connection to you can be established, for example, by anonymisation, do not constitute personal data. Processing (e.g., collection, storage, retrieval, consultation, use, disclosure by transmission, erasure or destruction) according to Art. 4 No. 2 GDPR always requires a legal basis or your consent. Processed personal data must be deleted as soon as the purpose of the processing has been achieved and where no longer any legally prescribed retention obligations have to be observed. Here you will find information on the handling of your personal data when visiting our platform. In order to provide the functions and services of our platform, it is necessary that we collect personal data about you. We also explain to you the nature and extent of the data processing, the purpose and the relevant legal basis and the period of storage in each case.

    This Data Protection Declaration applies only to this offer. It does not apply to other platforms to which we merely refer by a hyperlink. We cannot accept any responsibility that your personal data are dealt with in confidence on such third party platforms since we have no influence on the compliance of such companies with data protection provisions. Please inform yourself about the treatment of your personal data by such companies directly on those platforms.

  2. Controller

    The following companies are responsible for the processing of personal data on this platform:

    • FAROS Fiduciary Management AG, Franklinstr. 56, 60486 Frankfurt am Main
    • FAROS Consulting GmbH & Co. KG, Franklinstr. 56 , 60486 Frankfurt am Main
    • FAROS Cost Advisory GmbH, Franklinstr. 56, 60486 Frankfurt am Main
    • Strategic Family Office Advisors GmbH, Liebigstraße 53, Frankfurt am Main
  3. Provision and Use of the Platform/Server Logfiles

      a) Nature and Extent of Data Processing

      When you use this platform without otherwise transmitting data to us (e.g., by registration or use of the contact form) we collect, through server logfiles, technically necessary data which are automatically transmitted to our server including:

      • IP-Address
      • Date and time of the enquiry
      • Name and URL of the file accessed
      • Website from which the access comes (Referrer-URL)
      • Access status/HTTP-Status code
      • Type of browser
      • Language and version of the browser software
      • Operating system

      b) Purpose and legal basis

    • This processing is technically necessary so that our platform can be displayed to you. We also use the data to ensure the security and stability of our platform. Evaluations of your location will also be transmitted to the Asset Managers.

      The legal basis for this processing is Art. 6 (1) a) and f) GDPR. The processing of the said data is necessary for the provision of a platform and therefore serves a legitimate interest of our company.

    • c) Period of storage

    • As soon as the said personal data are no longer required to display the platform, they will be deleted. The recording of data to provide the platform and the storage of data in logfiles is absolutely necessary for the operation of the Platform. The user therefore has no right of objection in respect of these aspects. The storage can, in individual cases, continue if the law so provides.

  4. Use of Cookies

      a) Nature, Extent and Purpose of Data Processing

    • We use cookies. Cookies are small files sent by us to the browser of your terminal in the course of your visit to our platform and stored there. Some functions of our platform cannot be provided without the use of technically required cookies. Other cookies facilitate various analyses. For example, some cookies recognise your browser when you revisit our platform and transmit various information to us. We use cookies in order to simplify and improve the use of our platform. We can, by means of cookies, inter alia, make our internet site more user-friendly and efficient by, for example, understanding your use of our platform and anticipating your preferred settings (e.g., country and language settings). If third parties process information by means of cookies, they collect the information directly through your browser. Cookies do not cause any damage to your terminal.

      They cannot run any programmes or contain viruses. On our platform, various kinds of cookies are used the nature and function of which will be explained below. Temporary cookies/session cookies On our platform, temporary cookies/session cookies are used which are automatically deleted as soon as you close your browser. Those kinds of cookies make it possible to record your Session-ID. Various queries of your browser can thereby be assigned to a joint session and it is possible to recognise your terminal again on later visits to the platform. Permanent cookies Permanent cookies are used on our platform. Permanent cookies are cookies which are saved on your browser for a longer period and which can transmit information. The length of storage varies depending on the cooky. You can yourself delete permanent cookies through your browser settings. Third party cookies We use analytical cookies to observe anonymised user behaviour on our platform. We also use advertising cookies with which user behaviour can be followed for advertising and targeted marketing purposes. Social media cookies enable a connection to your social network to be established and the sharing of content from our platform within your network. Configuration of Browser Settings Most web browsers are so pre-set that cookies are automatically accepted. You can, however, configure your browser so that it accepts only certain cookies or even no cookies anymore. We point out, however, that you may not then be able to use all functions of our platform. By using the browser settings, you can also delete saved cookies in your browser. It is also possible to set your browser so that it informs you before cookies are saved. Since the functioning of the various browsers may differ, we would ask you to avail of the relevant help menu of your browser for the corresponding configuration possibilities. Deactivation of the use of cookies may require the storage of a permanent cooky on your computer. If you subsequently delete that cooky, you must deactivate the use of cookies again.

    • b) Legal Basis

    • Because of the purpose described, the legal basis for the processing of personal data with the use of cookies is Art. 6 (1) f) GDPR. If you have consented to the use of cookies on the basis of a notice (“Cookie-Banner”) issued by us on the Platform, the legal basis is also Art. 6 (1) a) GDPR.

    • c) Period of storage

    • As soon as the data transmitted by means of cookies to us are no longer required for the above purposes, we will delete that information. The storage can, in individual cases, continue if the law so provides.

  5. Data collection to take precontract measures and perform contract

      a) Nature and Extent of Data Processing

    • We collect personal data about you precontract and in the course of the contract conclusion. That includes, for example, first and family name, address, e-mail address, telephone number or bank account details.

    • b) Purpose and Legal Basis of the Data Processing

    • We collect and process the data exclusively for the purpose of contract performance and/or compliance with precontractual obligations.

      The legal basis for that is Art. 6 (1) b) GDPR. If you have already consented thereto, an additional legal basis is Art. 6 (1) a) GDPR.

    • c) Period of storage

    • The data will be deleted as soon as they are no longer required for the purpose of their processing.

      In addition, legal retention obligations may apply, for example, commercial or tax law retention obligations according to the Commercial Code or the Tax Code. If there are such obligations, we block or delete your data at the end of such retention obligations.

  6. Registration Possibility on the Platform

      a) Nature and Extent of Data Processing

    • You can register on our platform. If you register, we collect and save the data which you enter in the input mask (e.g., family name, first name, e-mail address). No passing on to third parties occurs.

    • b) Purpose and Legal Basis of the Data Processing

    • Your registration is necessary for the use of certain content and services on our platform and/or for the performance of a contract or the conduct of precontract measures. After the registration, you are free to have the personal data you entered on registration changed or deleted completely at any time from the data bank of the party responsible for the processing.

      The legal basis for the processing is, in the case of consent, Art. 6 (1) a) GDPR. If your registration is for the preparation of a contract conclusion, the legal basis is also Art. 6 (1) b) GDPR.

    • c) Period of storage

    • The data recorded in the course of registration will be stored by us for as long as you are registered on our website and will then be deleted. Legal retention obligations remain unaffected. In addition, your registered personal data will be deleted if you so wish and request us to do so.

  7. Data Transmission

    We pass on your personal data to third parties only if:

    1. you have expressly consented thereto under Art. 6 (1) a) GDPR
    2. it is legally admissible and necessary according to Art. 6 (1) b) GDPR for the performance of a contract with you or for the conduct of precontractual measures.
    3. there is a legal obligation to do so according to Art. 6 (1) c) GDPR. We are legally obliged to transmit data to state authorities e.g., tax authorities, social insurance carriers, health insurance funds, regulatory bodies and criminal investigation authorities.
    4. the transmission is necessary according to Art. 6 (1) f) GDPR in the legitimate interests of the company and to make, exercise or defend legal claims and there is no reason to assume that you have an outweighing interest worthy of protection in your data not being transmitted.
    5. we avail, according to Art. 28 GDPR, in the course of the processing, of external service providers (contract processors) which have been subjected to the obligation to deal carefully with your data.

    We avail of such service providers in the areas of:

    • Hosting/IT

    The transmission to external bodies in third countries takes place only within the EU, i.e., no processing occurs outside the EU or the EEA.

  8. Contact Form

      a) Nature and Extent of Data Processing

    • We offer you the possibility on our platform to contact us and the Asset Managers by means of a form provided. In the course of sending your enquiry by means of the contact form, this Data Protection Declaration is referred to for obtaining your consent.

      If you use the contact form, your following personal data will thereby be processed:

      • - Salutation
      • - First Name
      • - Last Name
      • - Title
      • - Firm
      • - Sector
      • - Position
      • - Street
      • - Street Number
      • - Postal Code
      • - Place
      • - Country
      • - E-Mail Address
      • - Telephone Number
      • - Reference
      • - Content of Message

    • b) Purpose and legal basis

    • Stating your e-mail address is for the purpose of answering your enquiry by e-mail. No transmission of your personal data to third parties arises from the use of the contact form.

      The legal basis for the processing is a consent according to Art. 6 (1) a) GDPR in the declaration of consent voluntarily completed by you and revocable for the future at any time.

    • c) Period of storage

    • The data entered by you on the contact form will be stored by us until you request that they be deleted, your consent to storage is revoked or the purpose of the data storage has ended (e.g., after the processing of your enquiry has been concluded). Mandatory legal provisions – in particular retention period obligations, for example, according to the Commercial Code or the Tax Code - remain unaffected.

  9. Newsletter

      a) Nature and Extent of Data Processing

    • There is the possibility on our platform to apply for a free regular e-mail newsletter. In order to be able to send you the newsletter regularly, we require from you your e-mail address.

      For sending the newsletter, we use the Double Opt-In procedure. That means that we will only send you an e-mail newsletter when you have expressly confirmed that you consent thereto. We then send you a confirming e-mail with which you will be asked to confirm, by clicking a corresponding link, that you wish in future to receive the newsletter from us. That serves to ensure that only you personally as owner of the stated e-mail address can apply for the newsletter. Your confirmation must be given shortly after receipt of the confirming e-mail since, otherwise, your newsletter application will be automatically deleted from our data bank. If you apply for the newsletter, we collect and store the data entered in the input mask (e.g., family name, first name, e-mail address). With the newsletter application, we also save your IP Address entered by the Internet Service-Provider (ISP) and the date and time of your application in order that we can later track a possible misuse of your e-mail address. With the confirming e-mail (Double-Opt in e-mail) sent for checking purposes, we also save the date and the time of the click on the confirmation link and the IP Address entered by the Internet Service-Provider (ISP).

    • b) Purpose and legal basis

    • The data collected by us with the application for the newsletter will be used exclusively for the purposes of advertising promotions by means of the newsletter.

      The processing of your e-mail address for the sending of the newsletter is based according to Art. 6 (1) a) GDPR and Art. 7 (2) No. 3 Act against Unfair Competition on the declaration of consent voluntarily completed by you below and revocable for the future by you at any time. In addition, the processing is based on Art. 6 (1) f) GDPR because of our legitimate interest in documenting evidence of the necessary consent.

    • c) Period of storage

    • Your e-mail address will be stored for as long as you wish to receive the newsletter. After the cancellation of the sending of the newsletter, your e-mail address will be deleted unless you have expressly consented to further use of your data.

  10. Tracking and Analysis Tools

    You will find an exact overview of the Web Analysis and Social Media Tools used by us here:

  11. Data Security and Security Measures

    We undertake to protect your privacy and to deal with your personal data in confidence. For those purposes, we take comprehensive technical and organisational security measures which are regularly reviewed and adjusted to technological advances. That includes, inter alia, the use of recognised encryption procedures (SSL or TLS). However, unencrypted disclosed data for example when sent by unencrypted e-mail may possibly also be read by third parties. We have no influence thereon. The individual user is responsible for the protection, by encryption or otherwise, of the data provided by him/her from misuse.

  12. Amendments to the Declaration of Consent

    We reserve the right to update this declaration at any time if necessary.

  13. Your Rights

    Here you will find your rights in relation to your personal data. Details thereon are contained in Artt. 7, 15-22 and 77 GDPR. You can contact the responsible body accordingly (No. 2).

      Right to withdraw your data protection law consent according to Art. 7 (3) sent. 1 GDPR

    • You can withdraw your consent to the processing of your personal data at any time with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

    • b) Right to Information according to Art. 15 GDPR

    • You have the right to obtain confirmation as to whether or not we process personal data concerning you. If that is the case, you have the right to information about the personal data and further information e.g., the purposes of the processing, the categories of personal data concerned, the recipients, the envisaged period for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period.

    • c) Right to rectification und completion according to Art. 16 GDPR

    • You have the right to demand the rectification without undue delay of inaccurate personal data. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed.

    • d) Right to erasure (‘right to be forgotten’) according to Art. 17 GDPR

    • You have the right to the erasure of personal data if they are no longer necessary. That is the case, for example, if your data are no longer necessary for the original purposes, you have withdrawn your data protection law consent or the data have been unlawfully processed.

    • e) Right to restriction of processing according to Art. 18 GDPR

    • You have the right to restriction of processing e.g., if you believe that personal data are inaccurate.

    • f) Right to data portability according to Art. 20 GDPR

    • You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.

    • g) Right to object according to Art. 21 GDPR

    • You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you.

      Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

    • h) Automated individual decision-making, including profiling according to Art. 22 GDPR

    • You have the right not to be subject to a decision based solely on automated processing, including profiling except in the case of the exceptions in Art 22 GDPR. No decision-making on the basis of solely automated processing occurs.

    • i) Right to lodge a complaint with a supervisory authority Art. 77 GDPR

    • You also have the right to lodge a complaint with a data protection supervisory authority at any time, for example, if you are of the opinion that the data processing is not in conformity with the data protection law provisions.