Privacy Policy
This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within the framework of providing our services, as well as within our online offering and the associated websites, features, and content, as well as external online presences, such as our social media profiles (collectively referred to as the “online offering”). Regarding the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible party
Family Trust Investor FTI GmbH
Maximilianstraße 52
80538 München
TELEPHONE: +49 89 2154 730 – 0
TELEFAX: +49 89 2154 730 – 99
E-MAIL: info@familytrust.de
VAT Identification Number: DE297086201
Registered Office: Munich
Commercial register: Munich District Court, HRB 214276
Managing Directors: Carsten Abdel Hadi, Andreas Augustin, Florian Schepp
Competent Supervisory Authority: Family Trust Investor FTI GmbH, as an asset management company, is subject to supervision by BaFin (Federal Financial Supervisory Authority), Marie-Curie-Straße 24-28, D-60439 Frankfurt am Main.
Types of processed data
– Inventory data (e.g., personal master data, names, or addresses)
– Contact data (e.g., email addresses, phone numbers)
– Inhaltsdaten (z.B., Texteingaben, Fotografien, Videos)
– Content data (e.g., text entries, photographs, videos)
– Usage data (e.g., visited websites, interest in content, access times) Meta/communication data (e.g., device information, IP addresses)
Categories of affected persons
Visitors and users of the online service (hereinafter collectively referred to as “users”).
Purpose of processing
– Provision of the online services, its features, and content
– Responding to contact inquiries and communication with users
– Security measures
– Reach measurement/marketing
Terminology used
‘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 reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
‘Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
‘Profiling’ means 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.
Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR; the legal basis for processing to fulfil our services and implement contractual measures and respond to enquiries is Art. 6 para. 1 lit. b GDPR; the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR; in the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis. The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR. The legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR. The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR. The processing of special categories of data (in accordance with Art. 9 (1) GDPR) is governed by the provisions of Art. 6 (4) GDPR.
Safety measures
We take appropriate technical and organisational 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 probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk. The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and separation of the data. We have also set up procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If we disclose data to other persons and companies (processors, joint controllers or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary to fulfil a contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we disclose, transfer or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only take place if it is done to fulfil 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 authorisations, we only process or leave the data in a third country if the legal requirements are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU (e.g. for the USA through the ‘Privacy Shield’) or compliance with officially recognised special contractual obligations.
Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements. You have the right to request the completion of the data concerning you or the correction of incorrect data concerning you in accordance with the legal requirements. In accordance with the legal requirements, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements. You have the right to request that the data concerning you that you have provided to us be received in accordance with the legal requirements and to request that it be transferred to other data controllers. You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of cancellation
You have the right to withdraw your consent with effect for the future.
Right of objection
You can object to the future processing of data concerning you at any time in accordance with the legal requirements. In particular, you may object to processing for direct marketing purposes.
Cookies and right to object to direct advertising
Cookies‘ are small files that are stored on users’ computers. Different information 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 their visit to an online service. Temporary cookies, or ‘session cookies’ or ‘transient cookies’, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. ‘Permanent’ or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. ‘Third-party cookies’ are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and provide information about this in our privacy policy.
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. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the browser settings. Please note that you may then not be able to use all the functions of this website.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in this privacy policy, 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 retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be 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 law reasons.
Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Data protection information in the application process
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. Applicant data is processed to fulfil our (pre-)contractual obligations as part of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, § 26 BDSG also applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is labelled, otherwise it results from the job descriptions and basically includes personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. Applicants can also voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data if this is necessary for the exercise of the profession).
If provided, applicants can send us their applications using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We therefore cannot assume any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or sending it by post. Instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post.
The data provided by applicants may be processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified revocation by the applicant, the deletion will take place after a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.
Talent-Pool
As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 para. 1 lit. a. and Art. 7 GDPR. The application documents in the talent pool will only be processed in the context of future job advertisements and the search for employees and will be destroyed after the deadline at the latest. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future and declare an objection within the meaning of Art. 21 GDPR.
Contacting us
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details will be used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. The information provided by users may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization. We delete the requests if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the content of the newsletter is specifically described when registering for the newsletter, it is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.
Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.
The newsletter and the performance measurement associated with it are sent on the basis of the consent of the recipients in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 para. 1 lt. f. GDPR in conjunction with. § Section 7 para. 3 UWG.
The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. We are interested in using 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 unsubscribe from the newsletter at the end of each newsletter. We may store the 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 that consent was previously given. The processing of this data is 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.
Newsletter – Rapidmail
The newsletter is sent by the mailing service provider rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg i.Br., Germany. You can view the data protection provisions of the mailing service provider here: https://www.rapidmail.de/datenschutzbestimmungen. The mailing service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR and an order processing contract pursuant to Art. 28 para. 3 sentence 1 GDPR. The mailing service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
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 mailing service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google LLC (“Google”). GDPR) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Further information on the use of data by Google, setting and objection options, can be found in Google’s privacy policy (https://policies.google.com/privacy) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data is deleted or anonymized after 14 months.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created from the usage 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 generally 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 them).
The processing of users’ personal data is based on our legitimate interests in effective user information and communication with users in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR. If the users are asked by the respective providers of the platforms for consent to the data processing described above, the legal basis for the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the opt-out options, we refer to the following linked information from the providers.
In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
– 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=Active.
– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers to integrate 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 are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. 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 analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offer, as well as being linked to such information from other sources.
Google Maps
We integrate the maps of the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
Functions and content of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the access to the above-mentioned content and functions to the users’ profiles there. LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy.. LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.