Legal matters
Legal matters
FINVIA Family Office GmbH (hereinafter "FINVIA" or "we", "us" or "our") takes the protection of your personal data very seriously. The purpose of this Privacy Policy is to provide you with comprehensive information about how we handle your personal data. This Privacy Policy applies to the handling of your personal data when you visit our website and in the context of our business relationship.
1. who is responsible and who can I contact?
FINVIA is responsible for the processing of your personal data as described below. You can contact the following office with regard to all data protection inquiries:
FINVIA Family Office GmbH
Oberlindau 54 - 56
60323 Frankfurt am Main
Phone: +49 (0) 69 273 1147 0
Fax: +49 (0) 69 273 1147 47
E-mail: info@finvia.fo
You can contact our company data protection officer at:
FINVIA Family Office GmbH
Data protection officer
Oberlindau 54 - 56
60323 Frankfurt am Main
Phone: +49 (0) 69 273 1147 0
Fax: +49 (0) 69 273 1147 47
E-mail: datenschutzbeauftragter@finvia.fo
2. what data does FINVIA process and where does it come from?
We collect and process various personal data from you depending on the specific processing situations. Below you will find a list of the data relating to the respective processing situation.
2.1 What data does FINVIA process when you visit the website?
When you use the internet services provided by FINVIA on the www.finvia.fo website, we process data about you, including the following
2.2 What data does FINVIA process when you contact FINVIA?
When you contact FINVIA, we regularly process only the personal data that is necessary for contacting you, in particular:
Personal data (first and last name),
Data for contacting you (postal address, telephone number, e-mail address, fax number).
2.3 What data does FINVIA process as part of an ongoing business relationship?
We process personal data as part of the initiation and implementation of an ongoing business relationship with you,
(i) that we have received from you, such as:
(ii) that we obtain from publicly available sources, such as:
(iii) that we create about you in the course of our business relationship, such as
We will be happy to provide you with specific information about the personal data processed about you. Please contact us at the address given in section 1.
3. for what purposes does FINVIA process your data and on what legal basis?
We process your personal data exclusively in accordance with and on the basis of the applicable provisions of the General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act ("BDSG"). In certain situations, we also process your personal data to fulfill legal obligations or on the basis of your express consent.
3.1 Based on your consent
If you have given us separate consent to process your personal data, we will process your personal data within the scope of and based on this consent. Consent may, for example, relate to the transfer of data to partner companies or the evaluation of your data for targeted advertising measures.
Consent is always voluntary. Refusal or withdrawal of consent will not have any negative consequences for you.
3.2 To fulfill contractual obligations
We regularly process your personal data in the context of an existing contractual relationship with you in connection with advice on investment decisions or the brokerage of financial services and products as well as the execution of your orders, including the necessary pre-contractual measures.
The purpose of the processing is determined in each case by the service commissioned, the product ordered or your order. In some cases, we also have to transfer data to group companies or other entities in third countries (countries outside the European Union or the European Economic Area, e.g. Switzerland, United States of America) for these purposes.
The details of the purpose and further conditions of processing can be found in the provisions of the respective contract.
3.3 On the basis of legitimate interests
Your personal data is also processed to protect our legitimate interests, unless your interests or fundamental rights and freedoms, which require the protection of your personal data, prevail.
Subject to an appropriate balancing decision in individual cases, we regularly assume that our legitimate interests prevail in the following non-exhaustive list of processing situations:
4. to whom does FINVIA pass on your data?
If necessary, FINVIA passes on your personal data to those bodies or provides access to them to those bodies that assist in the fulfillment of our contractual and legal obligations or have a legitimate interest in doing so. A transfer does not take place if there is no separate legal basis for the transfer or if your interests or fundamental rights and freedoms prevail.
In accordance with the obligations of a contract concluded with you, we may transfer your personal data to an external accounting company for the purpose of asset accounting.
In order to fulfill our contractual obligations and provide our services and products, we also forward your personal data to processors who process your personal data on behalf of FINVIA. Processors are, in particular, companies that provide services in the areas of information technology, telecommunications, telemedia, logistics, sales and marketing. In particular, we use third-party processors within the framework of a contract concluded with you for the provision of advice and brokerage of financial services in order to be able to fulfill our legal obligations in connection with the provision of advice or brokerage of financial services. Processors are contractually obliged to process the data exclusively for the purposes specified by FINVIA and to either delete or return the data upon termination of the assignment.
In addition, we transmit your personal data to those bodies for which you have given us your express and voluntary consent. As part of the provision of third-party services on our website, some personal data may be forwarded to third parties. Further information on this can be found in section 6.
5. does FINVIA transfer your data to third countries?
A transfer of your personal data to a third country only takes place within the framework of a contractual relationship concluded between you and us regarding advice on investment decisions and the brokerage of financial services and products, insofar as this is necessary for the fulfilment of our contractual obligations, e.g. for the execution of an individual financial transaction commissioned by you with a bank based in a third country.
Third countries are countries outside the European Union or the European Economic Area. When transferring personal data to a third country, we will regularly provide suitable guarantees, for example by concluding the European Commission's standard contractual clauses, to ensure that data is only transferred to a third country on the basis of a level of protection that complies with the GDPR.
6. what kind of cookies and tracking technologies does FINVIA use?
For the provision, maintenance and analysis of our Internet pages and their use, we use various third-party software tools that are regularly based on the use of cookies, web beacons or similar technologies (collectively referred to as "tracking technologies"). Tracking Technologies help us learn how you use our Services (e.g., the pages you view or the links you click and other actions you take with the Services), provide us with information about your browser and online usage patterns (e.g., IP address, log data, browser type, browser language, referring/exit pages and URLs, pages viewed, whether you opened an email, links clicked, etc.) and information about the devices you use to access our Services. Tracking technologies enable us to link the devices you use to access our services in such a way that we can recognize you on the various devices you use and contact you if necessary. In addition, content that you have accessed on one device may lead to the display of advertising or content relevant to you on another device.
You can limit the use of tracking technology by changing your browser settings. You can determine what access you grant us to your devices and whether and for how long cookies can be stored on your device. You can also delete cookies that have already been saved at any time. Please note that the functionality of our website may be impaired if all cookies are deactivated.
6.1 What are cookies?
A cookie is a small file that is transferred from the website's host server during the use of a website and stored on the user's device (desktop computer, laptop, tablet, smartphone, other Internet-enabled devices) by the browser used. Cookies are used to store information about the user and to be able to retrieve it when the website is called up again.
6.2 What are cookies used for?
Cookies help us understand how our websites are used, analyze trends, administer the website, track a user's movements around our website, gather demographic information about our user base as a whole, allow you to navigate between pages efficiently, remember your preferences and settings on our websites and generally improve your browsing experience. Cookies also help us to show you advertisements that match your interests and are relevant to you.
We process the data collected through Tracking Technologies to (i) remember information so that you do not have to re-enter it during your visit or re-visit, (ii) provide you with personalized content, including advertising, (iii) recognize you across multiple devices (iv) monitor the functionality and performance of our websites, (v) collect aggregate metrics regarding total number of visitors, aggregate traffic, usage and demographic patterns on our websites, (vi) diagnose and resolve technical issues, and (vii) otherwise plan and implement improvements to our website.
6.3 What types of cookies are used on our website?
The cookies used on our website can generally be divided into one of the following categories: Strictly Necessary Cookies, Analytical Cookies, Functional Cookies, Advertising Cookies or Social Network Cookies.
6.3.1 Strictly necessary cookies
These cookies are essential for the functioning of our website and enable you to move around our website and use its functions. Without these cookies, certain services that are necessary for the full use of our website cannot be provided.
6.3.2 Analysis cookies
We use these cookies to collect information about how users use our website, e.g. which pages are accessed and read most frequently, or how users move from one link to the next. All information that these types of cookies collect does not relate to an individual user, but is summarized and processed with the information of other users in aggregated form. The cookies provide us with analytical data on how our websites work and how we can improve them.
6.3.3 Functional cookies
These cookies allow us to save a specific selection you have made and to customize our website so that it offers you enhanced functions and content. These cookies can be used, for example, to save your language selection or country selection.
6.3.4. advertising cookies
These cookies are used to show you targeted advertising. These cookies are also used to limit the number of times you see an advertisement and to measure the effectiveness of a particular advertising campaign.
Such cookies can also store information about other websites you have already visited and make this data available for retrieval by other organizations, e.g. advertising partners. This allows you to be shown advertising and advertisements about our offers and services on other websites after you have visited our website.
6.3.5. cookies from social networks
In order to facilitate the exchange of content on the Internet, some of our websites may contain small software applications from third-party providers, e.g. Facebook, Twitter or LinkedIn, for the exchange of data. The cookies are not stored on your device by us, but by the third-party provider. We cannot control these cookies. For more information, you should therefore visit the websites of the third-party providers.
6.4 How long are cookies stored on my devices?
The storage period depends largely on whether it is a "persistent" or "session-related" cookie. Session cookies are deleted after you leave the website that set the cookie. Persistent cookies remain on your device, even after you have finished browsing, until they are deleted or until they have expired.
6.5 Third-party cookies
Some of the cookies stored on your device originate from us. Other cookies are stored on your device when you visit our website by third-party providers that we have previously integrated on our website. These third-party providers provide us with a specific function or service in connection with our website. Although we can control the selection of third-party providers, we have no influence on the use of cookies by the third-party provider. Some third parties may use advertising cookies.
The advertising industry in the European Union has developed a system that allows you to opt out of the use of such cookies. For more information, please visit www.youronlinechoices.eu. Further information on the use of cookies from a third-party provider can be found on the website of the respective provider.
Cookies from the third-party provider Google are used as part of the provision of our website. The use of the third-party provider is explained below.
6.5.1. use of "Google Analytics"
Our website uses the Google Analytics service, a web analysis service from Google, which allows us to analyze the use of our website, which is also in our legitimate interest. Google Analytics is used in the Universal Analytics version. This enables the cross-device collection of data from multiple devices, sessions and interactions and the linking to a user.
To use Google Analytics, a cookie is stored on the device you use to visit our website. The cookie is a text file that contains data about your use of our website and transmits it to a Google server. The data is stored and processed on Google's servers. Google will use the transmitted information to analyze and evaluate your use of our website on our behalf and on our instructions and to provide us with this information in the form of reports and activity displays.
The data processed by us as part of Google Analytics will be automatically deleted after 50 months. You can object to the processing of your data in the context of "Google Analytics" at any time with effect for the future by accessing the following link https://tools.google.com/dlpage/gaoptout?hl=de and following the instructions contained therein.
6.5.2 Use of "PostHog"
We use functions of the Posthog service in our service. These functions are offered by Posthog Inc, 965 Mission Street, San Francisco, CA 94103 USA. Posthog can record and reproduce your behavior on our website and our applications anonymously. The storage of this data is limited in time and is used exclusively to improve our service based on your needs.
Further information on this can be found in Posthog's privacy policy: https://posthog.com/privacy
6.5.2 Use of "Pardot"
We use the marketing automation "Pardot" from "Salesforce" (Salesforce.com, Inc. Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States, hereinafter: "Salesforce") to coordinate our offer. This involves storing the data you have entered in the forms on our website and creating a user profile within the management software for the purpose of coordinating and responding to your request. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interests lie in the effective coordination and response to our customer inquiries as well as the administration and management of interested parties. After the processing is no longer necessary, the processing may be restricted to compliance with existing mandatory statutory retention obligations. "Salesforce" also processes your data in the USA. There is no adequacy decision with the European Commission for the USA. So-called "standard contractual clauses" have been concluded with "Salesforce" to ensure compliance with an appropriate level of data protection. We will provide you with a copy of the standard contractual clauses on request.
Further information on data protection and the storage period at "Salesforce" can be found at: https://www.salesforce.com/de/company/privacy/
We also use the "Pardot" service to analyze the databases (lead generation), to measure our marketing expenditure and to improve our services. "Pardot" uses so-called "cookies" (see the "Tracking" section above), which are stored on your end device. With the help of cookies, "Pardot" processes the information generated about the use of our website and the forms by your end device - e.g. that you have called up a certain web page - and processes, among other things, the data mentioned in the section "Use of our website", in particular your IP address, browser information, the previously visited website and the date and time of the server request, for the purpose of statistical analysis of website use. "Pardot" will process this information in order to evaluate your use of our website. If users fill out a form on our website, this data is processed in "Pardot" and "Pardot" can assign the visit to an existing user profile. The legal basis for the processing is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. "Salesforce" also processes some of the data in the USA. There is no adequacy decision by the EU Commission for a data transfer to the USA; the legal basis for the transfer to the USA is your consent in accordance with Art. 49 para. 1 sentence 1 lit. a) GDPR. Your data in connection with "Pardot" will be deleted after fourteen months at the latest.
6.5.3 Use of Sentry
We use the Sentry service (Sentry, 1501 Mariposa St #408, San Francisco, CA 94107, USA) to improve the technical stability of our service by monitoring system stability and detecting code errors. Sentry serves these purposes alone and does not analyze data for advertising purposes. User data, such as information on the device or time of error, is collected anonymously and is not used for personal purposes and is subsequently deleted. Further information on this can be found in Sentry's privacy policy: https://sentry.io/privacy/ .
6.6. Can mobile devices determine my location?
If you use our website with a mobile device with location tracking enabled, we may be able to collect information about your current location, geocoordinates and geotargeting data as well as the type of mobile device. However, most mobile devices offer the option of deactivating location tracking in the settings. FINVIA does not use this service.
6.7 Right to object
You have the right to object to the processing of the data processed under this section 6. You can prevent the processing of this data by changing your browser settings. You may then only be able to use the Internet pages provided by us to a limited extent.
7. how long do we store your personal data?
We only process and store your personal data for as long as is necessary for our processing purposes.
7.1 Storage period in the context of the use of our online services
We will delete your personal data collected and stored in the context of the use and provision of our online services upon request at any time and independently at the earliest within a few days (regularly seven days), at the latest after expiry of statutory retention obligations.
7.2 Storage period as part of our business relationship
We generally only store your personal data as part of our business relationship for a maximum of four years after the end of your business relationship with us.
Insofar as a longer storage period is required due to statutory retention and documentation obligations or to protect our legitimate interests, e.g. in the event of possible legal disputes, your personal data will be stored and processed even after the above-mentioned period has expired. Where possible, we will block your personal data for further processing.
The periods resulting from the statutory retention and documentation obligations are between two and ten years and result from the German Fiscal Code, the German Money Laundering Act, the German Commercial Code, the German Banking Act and the German Securities Trading Act, among others.
8. your rights
The following is a summary of your rights with regard to the processing of your personal data by us:
8.1 Rights to information, erasure, rectification, restriction of processing and data portability
In accordance with Art. 15 GDPR, you have a right to information, according to which you can request confirmation as to whether we are processing your personal data. If this is the case, you have the right to request comprehensive information about this personal data from us.
In accordance with Art. 16 GDPR, you can demand that incorrect data concerning you be corrected immediately.
In accordance with Art. 17 GDPR, you have the right to request the erasure of your personal data if they are either (i) no longer necessary for the purposes for which they were collected, (ii) you have withdrawn your consent to processing, (iii) you have objected to processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for continued processing, (iv) your personal data have been unlawfully processed, (v) the erasure of the personal data is necessary for compliance with a legal obligation in Union or Member State law to which FINVIA is subject, or (vi) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
According to Art. 18 GDPR, you have the right to demand the restriction of processing under the following conditions. Such a right exists if you have either (i) disputed the accuracy of your personal data, (ii) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead, (iii) you no longer need the data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or (iv) you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether we have legitimate grounds for the processing which override yours.
According to Art. 19 GDPR, you have the right to request information about the recipients of data to whom a correction, deletion of your personal data or a restriction of processing has been communicated.
In accordance with Art. 20 GDPR, you have the right to receive the personal data concerning you from us in a structured, commonly used and machine-readable format and to transmit this data to another controller.
If the processing or transfer of your personal data is based on your consent, you can withdraw your consent at any time with effect for the future.
You also have the right to lodge a complaint against the processing of your data or a decision made by FINVIA in relation to one of the rights exercised by you with the Hessian Data Protection Commissioner, Postfach 3163, 65021 Wiesbaden.
8.2 Contact
For the assertion of your rights listed under section 8.1, you can contact us informally by post, fax or e-mail to the contact options listed under section. 1 contact options specified in section 1.
8.3 Right to object pursuant to Art. 21 GDPR
8.3.1. objection on grounds relating to your particular situation
In accordance with Art. 21 (1) GDPR, you have the right to object to the processing of your personal data at any time on grounds relating to your particular situation, if this processing is carried out for the purpose of our legitimate interests, including profiling based on these interests (e.g. for credit assessment). Your personal data will then no longer be processed unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.
8.3.2. contact
You can declare your objection informally by post, fax or e-mail, addressed to:
FINVIA Family Office GmbH
Oberlindau 54 - 56
60323 Frankfurt am Main
Phone: +49 (0) 69 273 1147 0
Fax: +49 (0) 69 273 1147 47
E-mail: info@finvia.fo
9. no obligation to provide personal data
In principle, you only have to provide us with the personal data that is necessary for our business relationship or that we are legally obliged to collect (e.g. mandatory information about your person to establish your identity in accordance with the general due diligence obligations of §§ 10 ff. of the German Money Laundering Act). Money Laundering Act).
Since we cannot provide our services or cannot provide them lawfully without the provision of the data required for the performance of the business relationship or the data that must be collected by law, we regularly refuse to enter into a contractual relationship in this case or reserve the right to terminate the ongoing contractual relationship if we can no longer provide the services under the contract.
10. automated decision-making and profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, if the decision is not necessary for the conclusion or performance of a contract, is not required by mandatory legal provisions or is not based on your express consent.
FINVIA does not use any automated decision-making processes, including profiling within the meaning of Art. 22 GDPR, unless we have explicitly informed you of this.
11. newsletter
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the newsletter at any time, for example via the link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after you unsubscribe from the newsletter. Data stored by us for other purposes remains unaffected by this.
We use our service provider (processor) MailChimp to send our newsletter.
The newsletter is sent using "MailChimp", a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on MailChimp's servers in the USA. MailChimp uses this information to send and analyze the newsletter on our behalf. Furthermore, MailChimp may, according to its own information, use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and presentation of the newsletter or for economic purposes in order to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
FINVIA relies on the reliability and IT and data security of MailChimp. MailChimp is certified under the US-EU data protection agreement "Privacy Shield" and thus undertakes to comply with EU data protection regulations. Furthermore, we have concluded a "Data Processing Agreement" with MailChimp. This is a contract in which MailChimp undertakes to protect the data of our users, to process it on our behalf in accordance with its data protection provisions and, in particular, not to pass it on to third parties. You can view MailChimp's privacy policy here.
etracker
The provider of this website uses the services of etracker GmbH from Hamburg, Germany (www.etracker.com) to analyze usage data. We do not use cookies for web analysis by default. If we use analysis and optimization cookies, we will obtain your explicit consent separately in advance. If this is the case and you give your consent, cookies are used to enable a statistical analysis of the reach of this website, to measure the success of our online marketing measures and test procedures, e.g. to test and optimize different versions of our online offering or its components. Cookies are small text files that are stored by the Internet browser on the user's end device. etracker cookies do not contain any information that enables a user to be identified.
The data generated with etracker is processed and stored by etracker exclusively in Germany on behalf of the provider of this website and is therefore subject to the strict German and European data protection laws and standards. etracker has been independently audited and certified in this respect and has been awarded the ePrivacyseal data protection seal of approval.
Data processing is carried out on the basis of the legal provisions of Art. 6 para. 1 lit. f (legitimate interest) of the General Data Protection Regulation (GDPR). Our concern within the meaning of the GDPR (legitimate interest) is the optimization of our online offer and our website. Since the privacy of our visitors is important to us, the data that may allow a reference to an individual person, such as the IP address, login or device identifiers, are anonymized or pseudonymized as soon as possible. No other use, combination with other data or transfer to third parties takes place.
You can object to the data processing described above at any time by clicking on the slider. The objection has no negative consequences. If no slider is displayed, data collection has already been prevented by other blocking measures.
Further information on data protection at etracker can be found here.