Being the operator of this website, advinda Investor Cloud GmbH, Prinzregentenstr. 54, 80538 München, Germany (hereinafter “we” or “us”), recognises itself to be the data controller with respect to the personal data collected from the users of its websites under https://advinda.com and in the advinda Investor Cloud app (both hereinafter “websites”). We are taking privacy and the right to self-determination very serious. To ensure that you are fully informed about the personal data being collected, processed and for which purposes, as well as your applicable rights, please note the following information.
- Name and address of the and the Data Protection Officer
Controller for the purposes of the General Data Protection Regulation (GDPR) is:
advinda Investor Cloud GmbH,
Prinzregentenstr. 54 80538 München, Germany
Email: administration@advinda.com
Tel: +49 89 809 13 43 00
Data Protection Officer:
PROLIANCE GmbH
www.datenschutzexperte.de
Leopoldstr. 21
80802 München
datenschutzbeauftragter@datenschutzexperte.de
- Collection of data and information as well as its usage and the purpose of processing
a) When visiting our websites
When visiting our sites, the browser that you use on your device, automatically transmits information to the server on which our website is hosted. This information is temporarily stored in a so-called log file. The following information is processed without your interaction and stored until automatically deleted:
- IP address of the device accessing the website,
- date and time of the access,
- name and URL of the file or page accessed
- the website from which a call to our website is made (the so-called referrer URL),
- browser and if applicable operating system used on your device as well as the name of your internet service provider.
The information listed is used by us for the following purposes:
- Ensuring that the content of the website are delivered correctly,
- optimizing the user-friendliness of our website,
- monitoring system security and stability as well as other
- administrative purposes.
Legal basis for processing of this data is Art. 6 (1) lit. f, GDPR, our legitimate interest in the above purposes. Under no circumstances is this data used for drawing conclusions on your person.
In addition to the above, we are using cookies on our website as well as web analytics services. Further information is listed under section 4 and 5 of this privacy policy.
b) When using our contact forms, including requests for online demonstration, trials, etc.
For all enquiries, we are offering you the opportunity to contact us via forms on our website. The forms require you to provide your company, name, email address and phone number so that we know from whom we are receiving the enquiry and to be able to respond to your enquiry. Further information that you share with us via these forms is voluntary.
Your personal data will be processed by us to protect our legitimate interests in accordance with Art. 6 (1) lit. f GDPR; our legitimate interest is to answer your inquiries appropriately. Alternatively if the request aims at the conclusion of a contract in accordance with Art. 6 (1) lit. b GDPR (for entering into or the performance of a contract). Legal processing of this data received by you via our forms can be based as well on Art. 6 (1) lit. a, GDPR if you provide your data voluntarily with your consent and give us the opportunity to respond to your .
c) When registering on our website and/or subscribing to our service
When you register with us, we require a name and email address and your company name from you. When you enter into a subscription agreement with us, we require further details such as credit card data, where applicable, and tax IDs. In using our service you may provide to us further information, for example information about investment campaigns, tasks, contact details of third parties and other content. If you use our team functionality to build a team with other registered users on the websites, such content with the exception of payment data will be disclosed by you to your team members. Please note that you are obliged to ensure that you are entitled to submit your content to the websites and, as the case may be, to share it with your team members. When a license for a data packages is transferred by you to another registered user, we will also collect and process this information. We will only use the sort of personal data which are necessary for us to provide the offered services. In addition to that, your personal data will only be collected, used, processed or transmitted to the extent such action is permitted by law and/or you have given your consent hereto based on Art. 6 (1) lit a, GDPR. Basis for the further processing after the registration and our confirmation of your registration is Art. 6 (1) lit b GDPR to fulfill our contractual obligations towards you.
d) When collecting publicly available data for provision of our service
We collect online public available business related information from various websites via data integration and analysis by means of web scraping and with the aid of artificial intelligence/machine learning/deep learning. We combine it with internal research results. We collect in addition to the data of companies, specific business data of relevant persons working on the board of directors, management, etc. in the different companies (hereinafter “Data Subjects”). This includes name, position in the company, department, business address, business phone and business email of the Data Subjects (hereinafter “Data”).
Further contact details of the Data Subjects will only be collected if the Data Subject identifies her/himself by sending us an email or if she/he gets otherwise in contact with us (see above, Section 2.b. or below Section 7 of this Privacy Policy). This data will be processed only for these purposes.
The information collected (including the Data) is administered, stored, analyzed, filtered and assigned to packages (data mining) in a specific database and stored on a specific platform (the “Cloud”) to which registered users have access. The registered users gain insights in the structure, asset allocation, performance and balance sheet figures of institutional investors. They can target and select suitable institutional investors. The package of investors needed can be selected e.g. by geography or by investor type. Furthermore information about relevant contacts is provided (the Data). The information is permanently updated so that real-time insights from publicly available data is possible. The information provided enables registered users to assess business opportunities, to take business decisions, to identify important business relationships and to improve their business.
Our processing of the Data is based on legitimate interests, Art. 6 (1) lit. f GDPR. The information collected can e.g. be used by the registered users in a structured way for strategic planning, to identify the right contact person for the companies’ activities and to improve their business relationships. A faster, more efficient and more targeted selection of the persons to contact is possible when using the Cloud.
Each Data Subject has the right to object to this processing of his/her personal data at any time and the right to exercise all other data subject’s rights available and described in Section 7 and 8 of this Privacy Policy. The objection may be made without formality and could be sent to the address mentioned in Section 8 of the Privacy Policy.
e) For legal compliance
We also process your personal data in order to fulfil other legal obligations that we are subject to in connection with the processing of our contracts or with our business communication. These include in particular retention periods under commercial, industrial or tax law.
We process your personal data for the above purposes to fulfil a legal obligation to which we are subject in accordance with Art. 6 (1) lit. c GDPR in connection with commercial, industrial or tax law, insofar as we are obliged to record and store your personal data.
f) For law enforcement
We also may process your personal data in order to assert our rights and enforce our legal claims and to be able to defend ourselves against legal claims, if applicable. Finally, we process your personal data as far as this is necessary to prevent or prosecute criminal offences.
We process your personal data to protect our legitimate interests in accordance with Art. 6 (1) lit. f GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or prevent or clarify criminal offences.
f) For sale of business, mergers, etc.
We may process your personal data in order to carry out a (partial) sale of a business or a merger (or similar operation such as acquisition in liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire the assets/capital, which may include your personal data, from us or we enter into or seek to enter into a merger with another company, we may need to provide that company with access to or transfer your personal data held by us for the purpose of reviewing and implementing the sale of the company/merger (e.g., to determine the value of the company, business risks, etc.).
We process your personal data for this purpose in order to protect our legitimate interests pursuant to Art. 6 (1) lit. f GDPR, in order to be able to plan and implement a planned sale of a company or a planned merger.
- Transfer of data
There is no transfer of your personal data for other than the below purposes:
We will transfer your personal data only:
- if you have given your express consent in accordance with Art. 6 (1) lit a, GDPR, the transfer is in line with Art. 6 (1) lit. f GDPR, necessary to claim, exercise or defend our rights and there is no reason to assume that you have a vital interest requiring protection from the transfer,
- in case that the transfer is based on Art. 6 (1) lit. c due to a legal obligation, as well as
- in case that the transfer is permitted by law and in line with Art.6 (1) lit. b, GDPR necessary for fulfilling our contractual obligations towards you.
In the following we name the categories of the recipients of your personal data:
- companies and their registered users who may be located worldwide when they use our Cloud to e.g. contact the representatives in charge and to keep track of (potential) business partners (see Section 2.d. of this Privacy Policy). After download of information from the Cloud, the companies and their registered users shall be responsible for any obligations under applicable law arising out of such usage, processing etc. including any information or consent obligations under applicable law; this Privacy Policy does not apply to any such usage, processing etc. by any of such companies or its registered users,
- IT service providers who, among other things, store data, support the administration and maintenance of the systems, as well as file archivists and shredders;
- third parties in connection with a sale, merger or other transfer of all or substantially all of our assets,
- public bodies and institutions insofar as we are legally obliged to do so.
In case personal data is transferred to service providers or group companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission to have an adequate level of data protection and other appropriate data protection guarantees (e.g., the agreement of EU standard contractual clauses) are provided. Nevertheless, due to the laws of non-EU states, even if these agreements and sets of rules are concluded, there is a possibility that government agencies in particular will access your personal data without us being able to prevent, stop or control this. For these reasons, your consent to the use of cookies, for example, also includes the purpose of data transfer to countries outside the EU. For further information please our Data Protection Officer (contact details see above Section 1).
Otherwise, we will not transfer your personal data to countries outside the European Union or European Economic Area or to international organizations.
- Cookies
We will as well collect information about your usage of our website by applying browser cookies. These are small text files which are placed on the hard drive of your computer as soon as you access the site so as to save specific settings and data exchange with our system via your browser. Cookies enable our systems to recognise your device and to render potential settings immediately available. The cookies will be saved on your hard drive until they expire or are deleted, so the websites recognizes your settings on each visit.
By way of applying cookies, we only collect and use the data concerning your usage of our website which is not effected by allocating the data to you personally, but by assigning an identification number to the cookie (“Cookie-ID”). If you do not wish to use cookies, you can set your browser to not accept cookies. Please note, that in this case you may only be able to use our websites to a limited extent or not at all. Already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. Regarding the use of web analytics tools and the related settings, please refer to Section 5 below.
- Analysis tools
a) Google Analytics
On our website we use Google Analytics, a web analytics service provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland (subsidiary of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use it. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymisation is activated on our website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address will be transmitted to a Google server in the USA and shortened there. Google will use this information on our be-half for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to us as the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
On our website, we use Google Analytics with the extension”_anonymizeIp()”. This means that IP addresses are processed in a shortened form, which excludes the possibility of a direct reference to a person.
We will process your personal data on the following legal bases:
· if you have given us your consent via the double opt-in process according to Article 6 (1) (a) GDPR;
· if you have given us your consent via the double opt-in process according to Paragraph 25 (1) TTDSG.
You can revoke consent once you have given it by
· preventing the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of our website;
· downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de or
· clicking this link to prevent Google Analytics from collecting data on our website in the future. This will place an opt-out cookie in your browser. Please note that you must activate the opt-out cookie in every browser you use on all of your end devices and that you may also have to reactivate it if you delete all cookies in a browser.
For more information on the terms of use and data protection of Google Analytics, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/
b) Google Adwords Conversion Tracking
To understand the use of our website and optimize our website further for you, we are using Google Conversion Tracking, a service of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland (subsidiary of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). For this purpose, a cookie will be placed on your machine in the case that you clicked a Google Ad to be directed to our site. These cookies will become invalid after 30 days and are not used to personally identify you. The data is used for statistical purposes only to find out how many users clicked an ad and were referred to our sites. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. A transfer of data by Google to third parties only takes place on the basis of legal regulations or within the framework of data processing.
Additional data processing will only take place if you have consented to Google linking your web and app browsing history to your Google account and using information from your Google account to personalize the ads you see on the web. In this case, if you are logged into Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with other Google data in order to form target groups.
We will process your personal data on the following legal bases:
· if you have given us your consent via the double opt-in process according to Article 6 (1) (a) GDPR;
· if you have given us your consent via the double opt-in process according to Paragraph 25 (1) TTDSG.
Revocation of your consent
We only use Google Ads with your consent. You can revoke consent once you have given it by preventing the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of our website.
For further information on the terms of use and data protection of Google Ads/DoubleClick, please visit https://www.google.de/intl/de/policies/.
c) Locally hosting of Google Web Fonts
This website uses web fonts provided by Google (Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA ) for the consistent visualization of fonts. We host Google fonts locally, i.e. only via our web servers and not via Google’s servers. When users visit our website, therefore, no IP addresses are transmitted to Google, there is no connection to the Google servers and no data transmission to or storage by Google in this respect.
We will process your personal data on the following legal basis:
· for the purposes of our legitimate interests according to Article 6 (1) (f) GDPR to be able to make our website technically available to you. In this respect, our legitimate interest consists in being able to make an attractive, technically functional and user-friendly website available to you and in taking measures to protect our website from cyber risks and in preventing cyber risks to third parties from our website.
If your browser does not support web fonts, a standard font from your computer will be used.
- Data security
Except as set forth under Section 5 above, any and all information which you transmit to us, is saved on servers within the European Economic Area. To the extent that personal data is being transmitted via the internet when using our websites and its services, we are not able to guarantee that the transmission of data via the internet is thoroughly safe. Therefore, in case you would like to provide us with any strictly confidential information, we advise you to do so by postal mail by using the following address: advinda Investor Cloud GmbH, Brienner Str. 14, 80333 Munich, Germany
However, we safeguard our websites and all of our systems against loss, destruction, unauthorised access, modification and distribution of your data by employing appropriate technical and organisational measures. In particular, your data will be encrypted before transmission. For this, we employ coding systems such as SSL Encryption.
- Your rights
With regards to our processing of your personal data the following applies:
- In accordance with Art. 15 GDPR, you are entitled to receive confirmation on your personal data processed by us, especially the purpose of the processing, the category of data processed, the category of recipients who were granted access to such data, the planned duration of storage, the existence of a right to correction, deletion, restriction or objection, the existence of a right to complain, the existence of the right to lodge a complaint with a supervisory authority the source of your data in as far as it was not retrieved by us, as well as information on any automated decision-making or profiling.
- In accordance with Art. 16 GDPR you are entitled to immediately demand the correction of incorrect or the completion of your incomplete personal data stored with us.
- In accordance with Art. 17 GDPR you may demand deletion of your personal data stored with us, in as far as the processing is not required to ensure the right of free speech and information, not required for fulfilling a legal obligation, for reasons of public interest or for exercising legal rights or protection from a legal claim.
- In accordance with Art. 18 GDPR you are entitled to demand restriction of processing of your personal data in as far as correctness of the data is contested by you, processing would not be legal, you however reject deletion of the data, we no longer require the data, you, however need them for exercising your legal rights and defend yourself against a claim; or if in line with Art. 21 GDPR you have objected to our processing of your data.
- In accordance with Art. 20 GDPR you may request to receive your personal data that you provided to us in a structured, common and machine-readable format or request the transfer of such data to another data controller.
- In accordance with Art. 7 (3) GDPR, you are entitled to revoke your consent to our processing of your data at any time. As a result, we are no longer entitled to continue processing of your data to which this consent was applicable.
- Your right to object
In as far as your personal data is processed on the basis of legitimate interest as per Art.6 (1) lit. f, GDPR you have the right to object to the processing of your personal data under Art. 21 GDPR in as far as a cause resulting from your particular situation exists or in cases of objecting to direct marketing. In the latter case you have a general right to object without having to indicate a particular cause and we will no longer process the data. To exercise your right to object, simply contact us – Email.
- Duration of the storage of personal data
The duration of the storage of personal data is determined by the respective statutory retention period (e.g. commercial and fiscal obligations). After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract, and/or if there is no legitimate interest on our side to maintain the data.
- Profiling and automatic decision-making
We are not using automatic decision-making or profiling.
- Scope of your obligation to provide personal data
Generally, you are not obliged to provide us with your personal data. However, if you do not do so, we cannot, for example, make our website available to you, answer your enquiries sent to us, send you information, etc. or enter into a contract with you.
- Amendments to our Privacy Policy
We reserve the right to modify our Privacy Policy from time to time at our own discretion while respecting the then current laws on data protection. An up-to-date version of our Policy is always available on our websites.
This privacy policy is valid as of January 1, 2023
