Data protection declaration of Dr. Kohlhase GmbH
Last update: 09/10/2020
Part I: General
1. Information about the collection of personal data
(1) We inform you below about personal data collected when using our website or getting in contact with us or close a contract with us. Personal data is all data that is can be obtained about you personally, e.g. name, address, e-mail addresses, user behaviour.
(2) The administrator pursuant to article 4 paragraph 7 of the EU General Data Protection Regulation (EU-GDPR) is Dr. Kohlhase Vermögensverwaltungsgesellschaft mbH, Löwengrube 18, 80333 Munich. You can reach our data protection coordinator at firstname.lastname@example.org or our postal address, for the attention of "the data protection coordinator".
(3) When you contact us by e-mail or via our contact form, we will store the information you have provided (your e-mail address, your name and your telephone number if necessary) in order to answer your questions. We delete the data generated for this purpose once its retention is no longer required or limit processing of the data if there are statutory retention requirements.
(4) If we rely on commissioned service providers for individual parts of our offer or would like to use your data for advertising purposes, we will inform you in detail below about the respective operations. We also list the criteria specified for the duration of retention.
2. Your rights
(1) You have the following rights with respect to personal data concerning you:
- Right to disclosure,
- Right to correction or deletion,
- Right to restriction of processing,
- Right to object to processing,
- Right to data transferability.
(2) You also have the right to submit a complaint to a data protection supervisory authority regarding our processing of your personal data.
3. Objection to or revocation of the processing of your data
(1) If you have given your consent to the processing of your data, you can revoke it at any time. Such revocation will affect the admissibility of processing of your personal data after you have communicated your revocation to us.
(2) Insofar as we base the processing of your personal data on a trade-off of interests, you may object to the processing. This is the case if, in particular, the processing is not required to fulfil a contract with you as set out in the description of the features below. If you do object to our processing of your data, we ask you to explain the reasons why we should not process your personal data as we have done. Based on your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you the compelling legitimate reasons for our continued processing of your data.
(3) You may of course object to the processing of your personal data for advertising and data analysis purposes at any time. You can inform us of your objection to advertising at the following address: mailadmin(at)kohlhase.de or our postal address in section 1. (2).
4. Client data
(1) Concluding an agreement with us will normally require you to provide us with further personal data (in particular, your personal details, further contact details and possibly also banking details, if needed) that we then use for the purposes of fulfilling the agreement, communicating with you prior to concluding the agreement as well as communication obligations pursuant to it. These details are subject to the aforementioned data processing principles. We cannot conclude and fulfil our agreements with you without processing this data.
(2) In the course of processing your personal data, we will be forwarding your personal data to government authorities and other relevant third parties, in particular to IT service providers, external data centres, banks, asset managers, auditors, tax advisers and solicitors.
(3) For the purposes of positively identifying our contractual partners, we may process biometric data included in identity documents (photo). This processing is required pursuant to the German Anti-Money Laundering Act (GwG) for reasons of substantial public interest.
(4) A soon as the aforementioned data is no longer required in the fulfilment of our contractual and statutory obligations, it is normally usually deleted, unless further processing of the data is required for the fulfilment of record-keeping obligations pursuant to commercial and/or tax legislation, such as the German Code of Commerce (HGB), the German Fiscal Code (AO), the German Banking Act (KWG), the German Anti-Money Laundering Act (GwG) or the German Securities Trading Act (WpHG) or for purposes of obtaining documentary evidence under German statute of limitation provisions.
5. Unsolicited applications
(1) We will consider unsolicited applications, and of course observe the confidentiality of the application documents.
(2) Where no vacancy is available for a given application, and no such vacancy is likely to arise in the foreseeable future, the respective application documents are deleted and/or disposed of appropriately. Otherwise, if the applicant is not chosen for the position, their application documents are deleted and/or disposed of after a period of three months has lapsed since the vacancy was filled, and the documents no longer need to be kept on file.
(3)Application documents may, however, be kept on file, if, with the permission of the applicant, they will be reconsidered in a subsequent application procedure. If the applicant wants the application documents deleted and/or disposed of, we will oblige without delay.
(4) Since all our electronic correspondence is automatically saved and stored for at least six years, the three-month period referred to under (2) above can only be observed in the case of applications submitted by email, if the documents were sent to the following address: personal(at)kohlhase.de.
Part II: Information relevant to website
1. An overview of data protection
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e. the “controller”)? The data on this website is processed by the operator of the website, whose contact information is available under section “Information Required by Law” on this website.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs please consult our Data Protection Declaration below.
2. General information and mandatory information
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Dr. Kohlhase Vermögensverwaltungsgesellschaft mbH
Phone: +49 (0)89 / 54 59 03-0
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties. Information about, rectification and eradication of data Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead
- of its eradication.
- If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
3. Recording of data on this website
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.
In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.
Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
4. Analysis tools and advertising
Matomo (formerly called Piwik)
This website uses the open source web analysis service Matomo. Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on our server. Prior to archiving, the IP address will first be anonymized.
Through Matomo, we are able to collect and analyze data on the use of our website by website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).
The use of this analysis tool is based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
6. Plug-ins and Tools
We are using the mapping service provided by OpenStreetMap (OSM). The provider of this service is the Open-Street-Map Foundation (OSMF), 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, United Kingdom.
When you visit any website, into which OpenStreetMap has been embedded, your IP address and other information concerning your behavior patterns on this website will be transferred to the OSMF. Under certain circumstances, OpenStreetMap will save cookies in your browser or uses comparable technologies for recognition.
We use OpenStreetMap with the objective of ensuring the attractive presentation of our online offers and to make it easy for visitors to find the locations we specify on our website. This establishes legitimate grounds as defined in Art. 6 Sect. 1 lit. f GDPR. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time