Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data” for short) that we process, for what 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.

Status: June 17, 2022

Table of contents

Responsible

Christian Thiele
c/o Block Services
Stuttgarter Str. 106
70736 Fellbach, Germany

E-mail address:

info@investmentgarage.de

Overview of processing operations

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.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

Categories of data subjects

  • Communication partners.
  • Users.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Management and response to requests.
  • Feedback.
  • Provision of our online services and user experience.
  • Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal bases of the DSGVO, on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on 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 employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security 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 nature, 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, 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 and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): 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 bar of your browser.

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where we have the consent of the data subjects or legal permission.

Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, 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 or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further information on the retention and deletion of data, which shall have priority for the respective processing operations.

Provision of the online offer and web hosting

In order 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, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

  • Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing processes, procedures and services:

  • Email sending and hosting: the web hosting services we use also include the sending, receiving as well as storing of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, 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. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta/communication data (e.g., device information, IP addresses); contract data (e.g., subject matter of contract, term, customer category).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; contact requests and communication; administration and response to requests; security measures.
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); consent (Art. 6 para. 1 p. 1 lit. a. DSGVO).

Further notes on processing operations, procedures and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right to process users’ details for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes. The personal information provided as part of the comments and contributions, any contact and website information as well as the content-related information will be stored by us permanently until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Comment subscriptions: 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 may unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving user consent, we store the time of subscription along with users’ IP address and delete this information when users unsubscribe. You may unsubscribe from receiving our subscription at any time, i.e., revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent formerly given. The processing of this data will be 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; legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO).
  • Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies – Within our WordPress blog, graphical emojis (or smilies), i.e., small graphic files expressing emotions, are used for purposes of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Website: https: //automattic.com; Privacy policy: https: //automattic.com/privacy.
  • Profile pictures from Gravatar: Profile pictures – We use the service Gravatar within our online offer and especially in the blog. Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave posts or comments on other online presences (especially blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of the transmission of the email address. It is not used for other purposes, but is deleted afterwards. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service. If users do not want a user image associated with their email address on Gravatar to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Website: https: //automattic.com; Privacy policy: https: //automattic.com/privacy.
  • UpdraftPlus: backup software and backup storage; service provider: Simba Hosting Ltd, 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Website: https://updraftplus.com/; Privacy policy: https: //updraftplus.com/data-protection-and-privacy-centre/.

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
  • Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further notes on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the requests and our legal retention obligations; Legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If, in the context of a registration for the newsletter, its contents are specifically circumscribed, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always 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.

Deletion and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: direct marketing (e.g., by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Option to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail, for this purpose.

Further information on processing, procedures and services:

  • SendinBlue: email marketing platform; service provider: SendinBlue SAS, 55, rue d’Amsterdam, 75008 Paris, France; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Website: https://de.sendinblue.com/; Privacy policy: https: //www.sendinblue.com/legal/privacypolicy/; Standard contractual clauses (ensuring level of data protection for processing in third countries): Provided by the service provider.

Modification and update of the privacy policy

We ask you to regularly check the content of our Privacy Policy. We will adapt the Privacy Policy as soon as the changes in the data processing operations carried out by us make it 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.

Insofar as we provide addresses and contact information of companies and organizations in this data protection declaration, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right torectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right 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.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
  • Complaint to supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Definitions

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • 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 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.
  • Controller: “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.
  • Processing: “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, whether collecting, evaluating, storing, transmitting or deleting.

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