PRIVACY POLICY

Responsible Authority

We are happy about your visit to our website. We would like to introduce ourselves as the responsible authority within the meaning of data protection law:

XVESTOR.APP
Sole proprietor Dr. Thomas Schön
Quellenstraße 7a
70376 Stuttgart
Phone: +49 711 – 96881941
E-Mail: info@xvestor.app

General Information

Pursuant to our statutory obligations, we would like to inform you about the collection and use of your personal data.

When you use our website, personal data about you will be collected. This may happen by you entering the data yourself, for example your e-mail address. But our system also collects your data automatically, for example whenever you visit our website. This happens irrespective of the device or the software that you use to visit our website.

All data that you enter in our app is provided voluntarily; there are no disadvantages to you if you do not provide data. But without certain data, we are unable to provide services or to conclude contracts. Whenever such information is necessary, we will point it out to you.

On this website, the user’s personal data is only collected within the framework of the existing data-protection law, in particular the General Data Protection Regulation (GDPR). The legal terms used in the text are defined in Art. 4 of the GDPR.

The GDPR allows data processing in three cases in particular:

  • in accordance with Art. 6 para. 1 (a) and 7 GDPR, when you have consented to us processing your data; in this Privacy Policy and in the cases of consent pursuant to Art. 4 no. 11 GDPR, we will inform you in detail and each time for what purposes and under what circumstances your data will be processed by us;
  • in accordance with Art. 6 para. 1 (b) GDPR, when processing your personal data is necessary for negotiating, concluding or performing a contract;
  • in accordance with Art. 6 para. 1 (f) GDPR, if the balancing of interests leads to the conclusion that the processing is necessary to protect our legitimate interests; this means in particular our interests to analyse, optimise and secure the offers on our website – meaning primarily the analysis of user behaviour, setting up profiles for advertisement purposes and storage of access data as well as the use of third-party providers.

Inventory Data, Usage Data

Inventory Data

We collect inventory data (for example name, address and e-mail address, possibly services used) insofar as they are required for establishing, defining or amending a contract between us and the user.

Usage Data

We also collect usage data (for example visits to the website, interest in products) to allow the user to use the services on our website and to invoice them.

We will only combine usage data if and insofar as it is necessary for billing purposes. Otherwise, we will only put together usage data pseudonymously and only insofar as you have not objected. You may send this objection to the address indicated in the “Legal Notice” section or the responsible authority indicated in this Privacy Policy at any time.

The legal basis for this data processing are our legitimate interests pursuant to Art. 6 para. 1 (f) GDPR in analysing the website and your use, possibly also the statutory permission to store data as part of the negotiation of a contract pursuant to Art. 6 para. 1 (b) GDPR.

Furthermore, our provider stores information, the so-called server log files, each time the website is used; this is information which is automatically transferred by your browser. In detail, this data consists of:

  • your IP address
  • type and version of your browser
  • host name
  • time of visit
  • the page from which you came to our page
  • name of the page opened
  • exact time of usage as well as
  • the amount of data transferred

This data will only be used for statistical purposes and do not allow us to identify you as a user.

Advertisements

Before sending you advertisements, we will ask for your explicit consent pursuant to Art. 4 no. 11 GDPR, except in cases of advertisements for similar products to the one you already acquired. This will happen in particular when you grant us consent to mail our newsletter or when you fill out a contact form.

You may withdraw your consent at any time in accordance with the subsequent section “Consent”.

INSOFAR AS WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING, YOU MAY ALSO OBJECT TO THE USE OF YOUR DATA FOR THAT PURPOSE AT ANY TIME. THIS MAY BE DONE THROUGH ANY OF OUR MEANS OF CONTACT, PARTICULARLY BY E-MAIL TO THE E-MAIL ADDRESS LISTED IN THE “LEGAL NOTICE” SECTION WITHOUT ANY FORMAL REQUIREMENTS. WE WILL THEN NO LONGER USE YOUR DATA FOR DIRECT MARKETING.

Consent

Whenever we ask you for your consent for the processing of your data, we will inform you in clear language and in an easily accessible way about the cases for which you will be granting your consent. Any consent that we ask you for is voluntary. Any advantage that you wish to gain by granting consent is also available without consent; simply ask us.

Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “Legal Notice” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

Storage Period

Your data will generally only remain stored for as long as the purpose of the relevant data processing requires it. Storage beyond that is mainly possible when it is still necessary for us to pursue our rights or for our other legitimate interests or if we are compelled by law to keep your data stored (for example based on tax-law requirements to maintain files, which is generally 6 years, but may last up to 10 years).

Cookies

Cookie Opt-Out

When you open the website, we have clearly pointed out to you that you can prevent the placing of certain cookies during your visit to our website by clicking on the opt-out button. If you have not done this, we assume your consent for using the cookies that have not been de-selected. You may withdraw your consent at any time without any formal requirements by sending us an e-mail or through the opportunities listed below.

As you have not objected, our website uses cookies based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR and based on your implied consent  pursuant to Art 6 para. 1 (a) GDPR, so that our offer can be used better, more effectively and more securely. Cookies are text files which are stored on your computer and which save certain data about your user behaviour on our page, so that, for example, an offer can be made to you based on your previous usage. These can be so-called “session cookies”, which will be automatically deleted at the end of your visit to our website. But there are also cookies that will be stored on your computer permanently, unless you delete them. This allows us to recognise your browser when you access our website the next time and to present you with offers that correspond to your previous use of our website.

Your browser allows you to prevent the use of cookies in specific cases or in general. Please consult the manual for your browser on this topic. See some examples below:

Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

Blocking cookies may limit the functionality of our and other websites that you visit.

Transfer of Data

Transfer to Third Parties

We dislike spam as much as you do. We will therefore not transfer your data to third parties, unless permitted by law.

Transfer of customer data may either

  • be required for the performance of a contract and in that case be permitted according to Art. 6 para. 1 (b) GDPR, or
  • be permitted based on our legitimate interest in an effective service structure pursuant to Art. 6 para. 1 (f) GDPR, or
  • covered by your consent pursuant to Art. 6 para. 1 (a) GDPR, or
  • become necessary if we will be legitimately asked by a government or an agency to hand over your data pursuant to Art. 6 para. 1 (c) GDPR.

If your data are transferred to third parties, this is mentioned in this privacy policy.

Transfer to other countries, particularly USA

Our website uses external providers located outside of the EU for different features. In particular, the use of cookies, active Java scripts and other technology can lead to processing and storage of your data outside of the EU. But we will not transfer your data to a third country, unless the EU Commission has determined that there is a similar level of data protection as in the EU or unless you have provided us with your informed consent or we have agreed on the standard contractual clauses for the protection of your data with the provider. Regarding the USA, the Privacy Shield Agreement – see https://www.privacyshield.gov/welcome – has re-established sufficient data protection under certain conditions.

You will find more information about your rights in the case of each of the data transfers to the USA mentioned subsequently at https://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf.

Users‘ Rights

Information

You may request us anytime to provide information about the personal data stored about you free of charge. To avoid misuse, this will require personal identification.

Deletion, Correction, Limitation

You may at any time demand from us that we correct (or complete) incorrect data as well as a limitation of the processing of data or deletion of your data. This applies in particular if the reason for processing the data is no longer valid, if a required consent has been revoked and there is no other legal basis or if our data processing is unlawful. We will then correct, block or even delete your personal data without delay as far as permitted by law.

Objection

The right to object to advertisement is governed by our text regarding consent:

Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “Legal Notice” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

Data Transfer

You may request us to transfer the data stored about you in machine-readable form.

Complaint

If you feel that our data processing has violated any of your rights, you may file a complaint with the competent regulatory agency (here you find a list of the agencies).

Changes to the Privacy Policy

If and when factual or legal reasons will compel us to amend the Privacy Policy, we will update this page accordingly. This will not change the consent provided by the user.

Newsletter

Newsletter, internal solution

If you subscribe to the newsletter offered on our page, we will inform you in detail about the information we will send you, which of your data will be stored and for what it will be used. We will not pass on your data to third parties and we will only use it for mailing the newsletter.

We will only mail you the newsletter if you have provided us with prior consent. To that purpose, you will receive an e-mail from us with a link and further details and we will ask for your consent. By confirming that link, you declare your consent to receive the newsletter and advertisement from us. Because we are legally required to record your consent as part of the double opt-in, your subscription to the newsletter, the mailing of our consent e-mail and your consent by clicking on the link will be recorded and stored with location and time as well as with your IP address.

The basis for the storage is your consent pursuant to Art. 6 para. 1 (a) GDPR, which you grant us when you register for the newsletter. You may withdraw that consent at any time, for which any notice to us, without any formal requirement, is sufficient (for example through the contact form or by e-mail or by using the link to unsubscribe, which is included in each e-mail). This withdrawal has no effect on the legality of the data processing carried out up to that point.

When mailing the newsletter, we do not use an external provider, but send all mails with our own mailing system. Therefore none of your data or your behavior will be forwarded to a third party. Our mailing system can inform us about the opening of the newsletter and/or the clicking on a link contained therein by you, but this information is just stored with us internally.

Your data remains stored, as long as it is part of our mailing list, as long as the storing is necessary to protect our rights or for other legitimate interests or if we are bound by law to keep your data longer.

Google

Google Analytics

Based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, we use the Google Analytics tool provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland. This allows to analyse the use of websites and to put together pseudonymous profiles of users based on the data. In order to do this, Google applies different technologies, among them also storing cookies on your computer. These store information about the use of our page, which we will use to improve our offers.

The data collected by Google may be transferred by Google to countries outside of the EU, in particular to the USA. Google has subjected itself to the Privacy Shield Framework; you can read more about your rights thereunder at

http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf

We have taken additional precautions to ensure the appropriate protection of your data as far as possible. Before transferring it to Google, we anonymize your IP address. This is achieved by activating the Anonymizelp() feature in the tracking code of Google Analytics.

We have also concluded a contract with Google about the processing of data, according to which Google will not combine your data with other data collected by Google in order to find out your identity.

If this should not be sufficient for you, you can also use the link http://tools.google.com/dlpage/gaoptout to download and install a browser plugin provided by Google to block Google Analytics, preventing Google from collecting and transferring your personal data.

You can also prevent the data collection by Google Analytics by confirming the subsequent link deactivate Google Analytics to deactivate Google Analytics by setting an opt-out cookie which will also prevent the collection of your data.

You will find more information about Google’s precautions regarding data protection at the following link:
https://policies.google.com/privacy?hl=en.

Additionally for the general handling with cookies, their deactivation and transfer of data to third parties (in particular USA) we refer to the general part of this declaration.

Google Tag Manager

With the Google Tag Manager, marketers can use an interface to administer website tags. The Tag Manager itself, which places the tags, works without cookies and collects no personal data. The Tag Manager only activates other tags, which may in turn collect data. About these third-party providers, you will find the respective declarations in this Privacy Policy. The Google Tag Manager does not use this data. If you have deactivated cookies, it will be respected for all tracking tags that were placed with the Google Tag Manager, so the tool does not change your cookie preferences.

Google may ask you for permission to pass on some product data (e.g. your contact information) to other google products in order to activate certain features, e.g. adding new conversion-tracking tags to simplify AdWords. Google’s developers will also check the information about the usage of the product from time to time, in order to further improve the product. But Google will never pass on such data to other Google products without your consent.

Further information can be found in the user guidelines of Google and the privacy policy of Google for this product.

This is our current valid privacy policy from 07.06.2019.