Table of contents
- 1.1Introductory information
- 1.3Competent Complaints Office
- 1.4Types of processed data
- 1.4.1Business-related processing
- 1.5Categories of affected persons
- 1.6Purpose of processing
- 1.7Terms used
- 1.8Legal basis
- 1.9Cooperation with contract processors and third parties
- 1.10Transmissions to third countries
- 2Rights of affected persons
- 2.1Right of revocation
- 2.2Right to object
- 2.3Cookies and right of objection for direct mail
- 2.4Deletion of data
- 3Data handling
- 3.1In the context of the website
- 3.1.2Collection of access data and log files
- 3.1.4Comments and Posts
- 3.1.5Comment subscriptions
- 3.1.6Appointment organization and management
- 3.1.7Registration Function
- 3.1.8Integration of third-party services and content
- 188.8.131.52Google Maps
- 184.108.40.206Google Fonts
- 3.1.9Range measurement with Matomo
- 3.2Newsletter, invitation distribution list & blog subscription
- 3.2.1Newsletter – Shipping Provider
- 3.2.3Newsletter – Performance Measurement
- 3.3Online presence in social media
- 3.4Other data processing
- 3.4.1Administration, Financial Accounting, Office Organization, Contact Management
- 3.4.2Provision of contractual services
- 3.4.3Provision of our statutory and business services
valueDACH Value Investing Community
to Tilman Versch
70374 Stuttgart Germany
Competent Complaints Office
Landesbeauftragte für Datenschutz Baden-Württemberg
70173 Stuttgart Germany
Types of processed data
- Inventory data (e.g., names, addresses).
- Contact details (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Additionally we process:
- Contract data (for example, contract object, term, customer category).
- Payment data (e.g., bank details, payment history)
- from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Categories of affected persons
- Visitors and users of the online offer (hereinafter referred to as “users”).
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answer contact requests and communicate with users.
- Security measures.
- Range measurement/marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
“Processing” means any operation carried out with or without the aid of automated procedures or any such series of operations in connection with personal data. The term goes a long way and covers practically every handling of data.
“Responsible” means the natural or legal person, authority, institution or other body that alone or together with others decides on the purposes and means of processing personal data.
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.
Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b DSGVO for contract fulfilment is necessary), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 DSGVO.
Transmissions to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of Art. 44 ff. Process DSGVO. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of affected persons
You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
They have correspondingly. In accordance with Article 16 of the DSBER, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 DSGVO.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request its transmission to other persons responsible.
In accordance with Art. 77 DSGVO, they also have the right to file a complaint with the competent supervisory authority.
Right of revocation
You have the right to revoke consents granted pursuant to Art. 7 para. 3 DSGVO with future effect
Right to object
You can object to the future processing of the data concerning you in accordance with Art. 21 DSGVO at any time. The objection may be lodged in particular against processing for direct marketing purposes.
Cookies and right of objection for direct mail
“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used 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. In such a cookie, for example, the content of a shopping basket can be stored in an online shop or a login jam. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration.
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.
Deletion of data
The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
In accordance with statutory requirements in Germany, the records are kept in particular for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).
In accordance with legal requirements in Austria, storage is carried out in particular for 7 years in accordance with § 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
In the context of the website
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offering.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f DSGVO in conjunction with. Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 letter f. DSGVO data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for a maximum of 7 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the information provided by the user for processing the contact enquiry and its processing is processed in accordance with Art. 6 para. 1 lit. b) DSGVO. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
Comments and Posts
When visitors write comments on the website, we store the data displayed in the comment form (especially name and e-mail address) for an indefinite period of time. This takes place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
The blog software used here stores IP addresses by default (e.g. for comments). However, this has been deactivated by using an appropriate plug-in and by modifying the code functions.
Subsequent comments may be subscribed to by users with their consent in accordance with Art. 6 para. 1 lit. a DSGVO. Users will receive a confirmation email to verify that they are the owner of the email address they 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 providing proof of user consent, we store the login dot along with the user’s IP address and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the e-mail addresses we have unsubscribed 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 these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Appointment organization and management
Via our website we offer Date organization and appointment management. Reservations are possible within the system. The information provided by the user (as a rule first name, surname and e-mail address) on the organisation of appointments is processed in accordance with Art. 6 Para. 1 lit. b) DSGVO during the reservation. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.
We delete the information if it is no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
Users can optionally create a user account. During the registration process, users will be provided with the required information. The data entered during registration will be used for the purpose of using the offer. Users can be informed by e-mail about information relevant to offers or registration, such as changes to the scope of offers or technical circumstances. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6 Para. 1 lit. c DSGVO. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
As part of the use of our registration and login functions as well as the use of user accounts, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary to pursue our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.
Integration of third-party services and content
We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. 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 include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.
Range measurement with Matomo
Newsletter, invitation distribution list & blog subscription
With the following information we inform you about the contents of our newsletter, our invitation distribution list and our blog subscription as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our valueDACH Newsletter, our Value Investing meetings and/or valueDACH Blog, you agree to the receipt and the described procedures.
- Content of the newsletter: We send newsletters, e-mails, e-mail invitations and e-mail notifications and other electronic notifications with (advertising) information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.
- Double opt-in and logging: The subscription to our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. The registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.
- Registration data: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name in the newsletter in order to address us personally. Please indicate your first and last name at the invitation distribution lists of the Value Investing meetings, as we invite you personally.
- Germany: The dispatch of the newsletter and the performance measurement associated with it is based on the recipient’s consent pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 no. 3 UWG or on the basis of the legal permission pursuant to § 7 para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.
Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the e-mail addresses we have unsubscribed 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 these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Shipping Provider
The shipping service provider can use the recipient’s data 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 newsletter or for statistical purposes. However, the shipping service does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.
We use the plugin “Official MailerLite Sign Up Forms” to make it easy and efficient to subscribe to our newsletter and our invitation distribution lists. This plugin connects to static.mailerlite.com from our website. This connection is necessary for the plugin to work. According to Mailerlite, no personal data is transmitted via this connection.
Newsletter – Performance Measurement
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 whose server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour, nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
We maintain online presence within social networks and platforms to communicate with active customers, prospects and users and to inform them about our services.
We would like to point out that user data can be processed outside the European Union. This can pose risks for users because, for example, the enforcement of users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they commit themselves to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created from the user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these).
The processing of users’ personal data is carried out on the basis of our legitimate interests in effective user information and communication with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers for consent to data processing (i.e. to give their consent e.g. by ticking a checkbox or confirming a button), the legal basis of processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the information provided by 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 data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) – Datenschutzerklärung: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads und http://www.youronlinechoices.com, Datenschutz: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Aktiv.
- Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Datenschutzerklärung: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Datenschutz: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Aktiv.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Datenschutzerklärung/ Opt-Out: http://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Datenschutzerklärung: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Datenschutz: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Aktiv.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Datenschutzerklärung/ Opt-Out: https://about.pinterest.com/de/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Datenschutzerklärung https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Aktiv.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland) – Datenschutzerklärung/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung
Other data processing
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, such as archiving. We process the same data that we process as part of the performance of our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.
Provision of contractual services
We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 (1) lit b. DSGVO. The entries marked as obligatory in online forms are required for the conclusion of the contract.
When using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 Abs. 1 lit. c DSGVO.
We process usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user e.g. product information based on their previously used services.
The data will be deleted after the expiry of statutory warranty and comparable obligations; the necessity of storing the data will be reviewed every three years; in the case of statutory archiving obligations, the data will be deleted after their expiry. Information in the possible customer account remain up to its deletion.
Provision of our statutory and business services
We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 Para. 1 lit. b. DSGVO, if we offer them contractual services or become active within the framework of an existing business relationship, e.g. with members, or if we ourselves are recipients of services and benefits. In all other respects, we process the data of data subjects in accordance with Art. 6 para. 1 lit. f. DSGVO on the basis of our legitimate interests, e.g. when administrative tasks or public relations work is involved.
The data processed here, the type, the extent and the purpose and the necessity of their processing are determined by the underlying contractual relationship. In principle, this includes inventory and master data of the persons (e.g., name, address, etc.), as well as the contact data (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, contents and information provided, names of contact persons) and if we offer payable services or products, payment data (e.g., bank details, payment history, etc.).
We delete data that is no longer required for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of business processing, we store the data for as long as it can be relevant for business transactions as well as with regard to any warranty or liability obligations. The necessity of data storage is reviewed every three years; in all other respects, the statutory storage obligations apply.