Privacy Policy

This privacy policy informs you on the type, the scope and the purpose of processing personal data (hereafter called ‘data’) within the framework of our service provision and our online presence. In respect of the usage of certain terms like ‘processing’ or ‘responsible’ we refer to art. 4 of the General Data Protection Regulation (GDPR).

Controller

Ickehorn Asset Management GmbH, Tegernseerstraße 104, Weissach, 83700 Kreuth
Germany

E-mail: ideas[a]ickehorn.de
Managing Director: Johann Preinsberger
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Types of personal data

• Master data (e.g. names, addresses)
• Contact data (e.g. E-Mail, phone number)
• Usage data (e.g. visited websites, access times)
• Meta/communication data (e.g. browser versions, ip-addresses)

Categories of data subjects

Visitors of this website and parties interested in our services (hereafter called ‘users’).

Purpose of processing

• Provision of our online presence and its content
• Replies to contact requests and communication with users
• Security measures

Definitions of used terms

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Appropriate legal basis

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), in the EU and the EEC, unless the legal basis in the data protection declaration is mentioned, the following applies:

The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR;

The legal basis for the processing for the fulfillment of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 (1) lit. b GDPR;

The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c GDPR;

The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR.

The processing of data for purposes other than those to which they have been granted is governed by the provisions of Article 6 (4) GDPR.

The processing of special categories of data (according to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.

Security measures

In accordance with legal requirements, we take into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the assumption of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copying of the data in accordance with legal requirements.

You have accordingly the legal requirements to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with the statutory provisions, you have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.

You have the right to request that the data relating to you provided to us be obtained in accordance with legal requirements and to request their transmission to other persons responsible.

You also have the right, in accordance with the legal requirements, to submit a complaint to the competent supervisory authority.

Right to withdraw consent

You have the right to withdraw granted consent with effect for the future.

Right to object

You may object to the future processing of your data in accordance with legal requirements at any time.

Erasure of data

The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy policy, the data stored by us is deleted as soon as it is no longer required for the according purpose and the deletion does not conflict with any statutory storage requirements.

Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That means that the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it.

We will notify you as soon as the changes require your participation (e.g. consent) or other individual notification.

Contractual services

We process the data of our contractual partners and interested parties as well as other clients (uniformly referred to as ‘contractual partners’) in accordance with Art. 6 (1) lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of its processing is determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

In principle, we do not process special categories of personal data, unless they are part of a contracted or contractual processing.

We process data that is necessary for the establishment and fulfillment of the contractual services and point out the necessity of its indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements.

The data will be deleted as soon as it is no longer required for the fulfillment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years. Otherwise the statutory storage obligations apply.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of fulfilling our contractual services. The processing principles are Art. 6 (1) lit. c. GDPR, Art. 6 (1) lit. f. GDPR. The processing affects customers, interested parties, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, and data archiving. These are all tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers.

Furthermore, based on our business interests, we store information about promoters and other business partners, e.g. for later contact. We generally store this majority of company- related data permanently.

Collection of access data and log files

We, respectively our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.