Privacy policy
Datenschutzerklärung
1. Section 1 - General information
1.1. Person responsible
The controller within the meaning of Art. 4 No. 7 GDPR is the person who alone or jointly with others determines the purposes and means of the processing of personal data.
With regard to our website, the operator is the:
Hauck & Aufhäuser Fund Services S.A. 1c, rue Gabriel Lippmann L-5365 Munsbach
Luxembourg
E-Mail: info-hafs@hal-privatbank.com Phone: +352 45 1314-500
Fax: +352 45 1314-519
Our data protection officer for HAFS and HALFI, DURY Consult GmbH, Obertorstraße 1, 66111 Saarbrücken, can be contacted at the following e-mail address dsb@dury-consult.com. The data protection officer for HALFI is Laura O'Doherty, who can be contacted at the following e-mail address VL-HALFI-Team@hauck-aufhaeuser.com.
1.2. Provision of the website and creation of log files
Please find here the data protection information for
- Customers of Hauck & Aufhäuser Fund Services S.A.
- Customers of HAL Fund Services Ireland Limited
- Customers of Hauck & Aufhäuser Administation Services S.A.
Each time our website is accessed, our system automatically collects data and information from the accessing device (e.g. computer, cell phone, tablet, etc.).
What personal data is collected and to what extent is it processed?
IP address of the accessing party; directory protection user; date; time; pages accessed; logs; status code; data volume; referrer; user agent; host name accessed.
This data is stored in the log files of our system. This technical data is not stored together with the personal data of a specific user, so that individual site visitors cannot be identified. The IP addresses are stored anonymously. For this purpose, the last one to three digits are removed, i.e. "127.0.0.1" becomes "127.0.0.0". IPv6 addresses are also anonymized. The anonymized IP addresses are stored for 60 days. This data is stored in the log files of our system for technical reasons, as this data is technically necessary when transferring data from servers to browsers when using the IP protocol and is automatically generated for technical reasons. The IP protocol data generated during data transmission enables us to merge the data with login attempts by a specific user in individual cases.
When using the registration or log-in function, this information can be assigned to the user account after successful login. We do not evaluate the log data for advertising or operational purposes, but only in individual cases for security reasons, as explained in the following purpose.
Legal basis for the processing of personal data
Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest to ensure the achievement of the purpose described below.
Purpose of data processing
The temporary (automated) storage of data is necessary for the course of a website visit in order to enable delivery of the online booking portal in the form of a website. Personal data is also stored and processed to maintain the compatibility of our website for as many visitors as possible and to combat misuse and troubleshooting. For this purpose, it is necessary to log the technical data of the accessing computer in order to be able to react as early as possible to display errors, attacks on our IT systems and/or errors in the functionality of our website. In addition, we use the data to optimize the website and to generally ensure the security of our IT systems.
However, we reserve the right to evaluate log file data for security reasons in the event of abusive login attempts for individual user accounts in order to prevent effective countermeasures for abusive page access and attacks on our technical systems.
Duration of storage
Information on the directory protection user used is anonymized after one day. Error logs, which record incorrect page views, are deleted after seven days. In addition to the error messages, these contain the accessing IP address and, depending on the error, the website accessed. Access via FTP is logged with anonymized user name and IP address and stored for 60 days. The mail logs for sending e-mails from the web environment are anonymized after one day and then retained for 60 days. During anonymization, all data on the sender/recipient etc. is removed. Only the data on the time of sending and the information on how the e-mail was processed (queue ID or not sent) are retained. Mail logs for sending via our mail servers are deleted after four weeks. The longer retention period is necessary to ensure the functionality of the mail services and to combat spam. Other technical data is deleted as soon as it is no longer required in order to ensure the compatibility of the website for all visitors.
Objection and deletion option
You can object to the processing at any time in accordance with Art. 21 GDPR and request the erasure of data in accordance with Art. 17 GDPR. You can find out which rights you are entitled to and how to them at the bottom of this privacy policy.
1.3. General information on making contact
Please note that in the case of unencrypted communication by e-mail or fax, complete data security on the transmission path to our IT systems cannot be guaranteed, so that we cannot guarantee the security of information with a high level of security.
For reasons of confidentiality, we expressly recommend encrypted communication or the postal service. Transmission by e-mail or fax involves the following risks, among others:
- personal data could be disclosed to third parties without authorization if the e-mail address or fax number is not entered correctly;
- You have no information on the recipient side, e.g. which or how many employees have access to the e-mail or fax;
- The transmission of data by e-mail or fax via several distributed intermediaries means that unauthorized third parties can access the data without encryption.
1.4. Processor
Some processors are with regard to our website. If they used for a special function (e.g. contact form) or a web service, they will be explicitly named at that point. The following additional processors are used here:
- Mittwald CM Service GmbH & Co KG, Königsberger Str. 4 - 6, 32339 Espelkam (hoster)
- i:punkt Agentur für Marketing und Internetlösungen GmbH & Co. KG, Düsseldorfer Straße 269, 45481 Mülheim an der Ruhr, Germany processed.
Your data is processed on the basis of an order processing contract in accordance with Art. 28 GDPR, which the legal basis for the transfer of data to this company. In addition, further measures have been taken to protect personal data.
2. Section 2 - Operation of the website
2.1. Contact form
What personal data is collected?
When using the contact form, it is mandatory enter a name, an e-mail address and a message. The e-mail address and request, as well as the name, are checked and processed by us. If justified by the purpose, we will also transfer the data to other companies in our group of companies. A transfer to the following companies is possible:
- Hauck & Aufhäuser Administration Services S.A., 1c, rue Gabriel Lippmann, L-5365 Munsbach
- Hauck & Aufhäuser Administration Services S.A., 1c, rue Gabriel Lippmann| L-5365 Munsbach
- HAL Fund Services Ireland, 26-27 Mount Street Upper, Dublin 2, D02 F890
Legal basis for the processing of personal data
The legal basis for the transmission to the controller and the affiliated companies is your consent when sending the contact form. Consent to processing and transmission is therefore based on Art. 6 para. 1 lit. a GDPR. Please note that further legal bases may be relevant in the course of processing the request, such as contract fulfillment or the fulfillment of legal obligations.
Purpose of data processing
The purpose of processing the e-mail address is to allocate your request in our system and to transmit responses to the message you have entered by us or the respective responsible company from our group of companies. In the course of processing, we check the request you have submitted via the contact form and assign it the correct contact person based on our internal group of companies, who will then get in touch with you. The name is used by the respective contact person to address you personally. To ensure that the most suitable contact person is available to you, you allow us to forward the request to the respective partner within the corporate group with your consent. Your inquiry will then be processed by the respective member of the group of companies.
Duration of storage
The data will be stored by us for as long as is necessary to fully answer the request. We will delete the data at the latest when there are no longer any statutory retention obligations.
Revocation and deletion option
The revocation and deletion options are based on the general regulations on the right of revocation and deletion under data protection law described below in this data protection declaration. You can withdraw your consent at any time. This does not affect the processing of the data collected up to this point.
Necessity of providing personal data
The provision of this data is neither legally nor contractually required. If you do not provide this information, you will unfortunately not be able to send a contact request.
2.2. Recall request
What personal data is collected?
When using the callback request, it is mandatory to enter a name and telephone number. If justified by the purpose, we will also transmit the data to other companies in our group of companies. Transmission to the following companies is possible:
- Hauck & Aufhäuser Administration Services S.A., 1c, rue Gabriel Lippmann, L-5365 Munsbach
- Hauck & Aufhäuser Administration Services S.A., 1c, rue Gabriel Lippmann| L-5365 Munsbach
- HAL Fund Services Ireland, 26-27 Mount Street Upper, Dublin 2, D02 F890
Legal basis for the processing of personal data
The legal basis for the transfer to the controller and the affiliated companies your consent when sending the callback request. Consent to processing and transmission is therefore based on Art. 6 para. 1 lit. a GDPR. Please note that further legal bases may be relevant in the course of processing the request, e.g. performance of a contract or fulfillment of a legal obligation.
Purpose of data processing
The purpose of processing the telephone number is to assign your request in our system and to enable us or the respective responsible company from our group of companies to call you back. The name is used for personal contact and verification by the respective contact person. To ensure that the most suitable contact person is available to you, you allow us with your consent to forward the inquiry to the respective partner in the group of companies. Your request will then be processed by the respective member of the group of companies.
Duration of storage
The data will be stored by us for as long as is necessary to fully respond to the callback request. We will delete the data at the latest when there are no longer any statutory retention obligations.
Revocation and deletion option
The revocation and deletion options are based on the general regulations on the right of revocation and deletion under data protection law described below in this data protection declaration. You can withdraw your consent at any time. This does not affect the processing of the data collected up to this point.
Necessity of providing personal data
The provision of this data is neither legally nor contractually required. If you do not provide this information, you will unfortunately not be able to send a callback request.
2.3. Web services
Google Analytics
On our website we use the Google Analytics service provided by Google Ireland Ltd, Gordon House, Barrow Street, 4 Dublin, Ireland, e-mail: support-deutschland@google.com, Website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision on the EU-US Data Privacy Framework of the EU Commission within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684- ae60- be03fcb0fddf_en ). The operator of the service is certified under the DPF, so that the usual level of protection of the GDPR applies to the transmission.
The legal basis for the processing of personal data your consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, which you have given on our website.
Google Analytics is a web tracker that analyzes the behavior of site visitors and their interactions with our website and provides us with evaluations and forecasts about the content and products of our website and their popularity (so-called tracking). We have integrated Google Analytics so that the service can compile an analysis of the surfing behavior of site users. For this purpose, Google collects the page interactions of page visitors with our website and, if applicable, existing information resulting from the reading of cookies or other storage technologies and prepares it statistically for us. Google Analytics uses data processing technologies that make it possible to track individual site visitors and their interaction with other Google services, such as the Google Ads advertising network.
Data from other Google services is also used to close data gaps using machine learning technologies, modeled statistics and forecasting functions and to compile comprehensive statistics on the content of our website. If Google Analytics is activated on our website, the data collected by Google Analytics is transferred to servers of Google Ireland Limited. As part of order processing, personal data may also be transmitted to the servers of the parent company Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. We carry out the analysis using Google Analytics in order to constantly optimize our website and make it more accessible. This is a so-called reach measurement.
For the processing itself, the service or we collect the following data: Data on the interactions of site visitors with the content of the website, data on the handling of the services displayed on our website, data from external Google services, insofar as they interact with our website, such as advertising data or data on behavior in relation to advertising, data on the rough geographical origin, the browser used, operating system and other information on the end device used.
Google Analytics will store the data relevant for the provision of web tracking for as long as it is necessary to fulfill the booked web service. Data collection and storage is anonymized. Insofar as individual interactions of site visitors make it possible to subsequently establish a personal reference to specific actions, we will delete the collected data when the purpose has been achieved. The data will be deleted at the latest when it is not subject to any statutory retention obligations. As a rule, we will delete this data after 12 months at the latest. The certification of the provider under the EU-US Data Privacy Framework can be at https://www.dataprivacyframework.gov/list.
You can withdraw your consent at any time. You can find more information on withdrawing your consent either in the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://tools.google.com/dlpage/gaoptout?hl=de.
Google Tag Manager
We use the Google Tag Manager service provided by Google Ireland Ltd, Gordon House, Barrow Street, 4 Dublin, Ireland, e-mail: support- deutschland@google.com, website: https://www.google.com/ on our website. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision on the EU-US Data Privacy Framework of the EU Commission within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684- ae60-be03fcb0fddf_en
). The operator of the service is certified under the DPF, so that the usual level of protection of the GDPR applies to the transmission.
The legal basis for the processing of personal data your consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, which you have given on our website.
Google Tag Manager provides a technical platform executing and controlling other web tools and web tracking programs by means of so-called "tags". In this context, Google Tag Manager stores cookies on your computer and, if web tracking tools are executed using Google Tag Manager, analyzes your surfing behavior (so-called "tracking").
The data generated by the "tags" are merged, stored and processed by Google Tag Manager under a uniform user interface. All integrated "tags" are listed separately in this privacy policy. When using our website with activated integration of "tags" from Google Tag Manager, data such as your IP address and your user activities are transmitted to Google servers. The tracking tools used in Google Tag Manager ensure that the IP address of Google Tag Manager is anonymized before transmission by anonymizing the source code. Tag Manager can be used to link and evaluate measurement values from different service providers (Google and third-party providers) on the basis of so-called tag management. Google Tag Manager helps us to compile reports on website activity and to control the web tools on our website.
For the processing itself, the service or we collect the following data: Cookies, web tracking data, outgoing or incoming links, information collected during the integration and activation of JavaScript code on the website created by Google Tag Manager and the web tools triggered by Google Tag Manager.
You can access the provider's certification under the EU-US Data Privacy Framework at https://www.dataprivacyframework.gov/list.
You can withdraw your consent at any time. You can find more information on withdrawing your consent either in the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://policies.google.com/privacy.
YouTube
We use the YouTube service provided by Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support- deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision on the EU- US Data Privacy Framework of the EU Commission within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d- 4684- ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so that the usual level of protection of the GDPR applies to the transmission.
The legal basis for the processing of personal data your consent in accordance with Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, which you have given on our website.
Videos from the YouTube platform are integrated into our website via the YouTube service. This integration allows us to show you videos directly on our website. In this way, site visitors can view information about our services without having visit the YouTube platform.
The service or we collect the following data for processing: Data to display the stream, data on videos clicked on, playlists created, ratings and comments, information on the end device used, the user's IP address and browser and other data from Google services to provide the video in accordance with the Google Privacy Policy
If YouTube is activated on our website and a video played, our website establishes a connection to the servers of Google Ireland Limited and transmits the data required to display the stream or video. As part of order processing, personal data may also be transmitted to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is a adequacy decision on the EU-US Data Privacy Framework of the EU Commission within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en). The operator of the service is certified under the DPF, so that the usual level of protection of the GDPR applies to the transmission.
When YouTube videos are displayed on our website, YouTube may transmit and process information from other Google services in order to provide background services for the video, such as streaming data. For this purpose, data may also be transmitted to the Google services Google Fonts, Google Apis, Google Video, Doubleclick. You can access the provider's certification under the EU-US Data Privacy Framework at https://www.dataprivacyframework.gov/list.
You can withdraw your consent at any time. You can find more information on withdrawing your consent either in the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also an opt-out option at https://support.google.com/My-Ad-Center- Help/answer/12155451?hl=en.
Consent Manager
We use the Consent Manager service from consentmanager AB, Håltegelvägen 1b, 72348 Västerås, Sweden, e-mail: info@consentmanager.net, Website: http://www.consentmanager.net/. The transfer of personal data takes place exclusively to servers in the European Union.
The legal basis for the processing Art. 6 para. 1 lit. c GDPR. The use of the service helps us to comply with our legal obligations.
By integrating the Cookie Consent Manager, we fulfill our legal obligation with regard to the consent management required for cookies.
The rights to which you are entitled with regard to processing can be found at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://www.consentmanager.net/datenschutz/.
Cookies
What personal data is collected and to what extent is it processed?
We integrate and use cookies on various pages to enable certain functions of our website and to integrate external web services. Cookies are small text files that your browser can store on your access device. These text files contain a characteristic string of characters that uniquely identifies the browser when you return to our website. The process of saving a cookie file is also referred to as "setting a cookie". Cookies can be set both by the website itself and by external web services. The cookies are set by our website or the external web services in order to maintain the full functionality of our website, to improve user-friendliness or to pursue the purpose stated with your consent. Cookie technology also enables us to identify individual visitors using pseudonyms,
e.g. individual or random IDs, so that we can offer more personalized services. Details are listed in the table below.
Legal basis for the processing of personal data
Insofar as the cookies are processed on the basis of consent pursuant to Art. 6 para. 1 lit. a GDPR, this consent is also deemed to be consent within the meaning of Section 25 para. 1 TDDDG for the setting of the cookie on the user's terminal device. Insofar as another legal basis is stated under the GDPR (e.g. for the performance of a contract or to fulfill legal obligations), the storage or setting is based on an exception in accordance with Section 25 (2) TDDDG. This is the case "if the sole purpose of storing information in the end user's terminal equipment or the sole purpose of accessing information already stored in the end user's terminal equipment to carry out the transmission of a communication over a public telecommunications network" or "where the storage of information in the end-user's terminal equipment or access to information already stored in the end-user's terminal equipment is strictly necessary to enable the provider of a digital service to provide a digital service explicitly requested by the user". The relevant legal basis can be found in the cookie table listed later in this section.
Purpose of data processing
The cookies are set by our website or the external web services in order to maintain the full functionality of our website, to improve user-friendliness or to pursue the purpose stated with your consent. Cookie technology also enables us to recognize individual visitors by means of pseudonyms, e.g. individual or random IDs, so that we can offer more individual services. Details are listed in the table below.
Duration of storage
Our cookies are stored until they are deleted in your browser or, if it a session cookie, until the session has expired. Details are listed in the following table.
Possibility of objection and removal
You can set your browser according to your wishes so that the setting of cookies is generally prevented. You can then decide on a case-by-case basis whether to accept cookies or to accept cookies in general. Cookies can be used for various purposes, e.g. to recognize that your access device is already connected to our website (permanent cookies) or to save recently viewed offers (session cookies). If you have expressly given us permission to process your personal data, you can revoke this consent at any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of your consent until you withdraw it.
3. Section 3 - Your rights
3.1. Right to information
You have the right to request confirmation as to whether we are processing your personal data. If this is the case, you have a right of access to the information specified in Art. 15 (1) and (2) GDPR. We will also be happy to provide you with a copy of the data, provided that the rights and freedoms of other persons are not affected (see Art. 15 para. 4 GDPR).3.2. Right of rectification
In accordance with Art. 16 GDPR, you have the right to have any incorrect personal data stored by us (e.g. address, name, etc.) corrected at any time. You can also request the completion of the data stored by us at any time. A corresponding adjustment will be made immediately.3.3. Right to erasure
Pursuant to Art. 17 (1) GDPR, you have the right to demand that we erase the personal data collected about you if- the data no longer required;
- the legal basis for processing no longer applies due to the withdrawal of your consent;
- you have objected to the processing and there are no overriding legitimate grounds for the processing;
- your data processed unlawfully;
- a legal obligation requires this
- a collection pursuant to Art. 8 para. 1 GDPR has taken place.
- the processing is necessary for exercising the right of freedom of expression and information;
- your data been collected on the basis of a legal obligation;
- the processing necessary for reasons of public interest;
- the data is required for the establishment, exercise or defense of legal claims.
3.4. Right to restriction of processing
Pursuant to Art. 18 (1) GDPR, you have the right in individual cases to request the restriction of the processing of your personal data. This is the case if- the accuracy of the personal data is disputed by you;
- the processing is unlawful and you do not consent to erasure;
- the data no longer required for the purpose of processing, but the data collected serve to assert, exercise or defend legal claims;
- an objection to the processing pursuant to Art. 21 (1) GDPR has been lodged and it is still unclear which interests prevail.
3.5. Right of revocation
If you have given us your express consent to process your personal data (Art. 6 para. 1 lit. a GDPR), you can withdraw this consent at any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.3.6. Right to object
If you no longer want us to your data when storing and processing it due to a special situation, you can object at any time to data that we have collected on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest) in accordance with Art. 21 GDPR.
3.7. Right to data portability
Upon request, we will provide you or a controller designated by you with the following data in a commonly used, machine-readable format in accordance with Art. 20 (1) GDPR- Data collected on the basis of express consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR;
- Data that we have received from you in accordance with Art. 6 para. 1 lit. b GDPR within the framework of existing contracts; insofar as the data has been processed within the framework of an automated procedure.