I. Name and address of the responsible party
The responsible party within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other
data protection provisions is:
One Square Advisors GmbH
80333 Munich Germany
Phone: +49 89 15 98 98-0
Email: info [at] onesquareadvisors [dot] com
II. Name and address of the data protection officer
Your contact person in the area of data protection is:
Data Protection Officer
III. General information on data processing
1. Scope of processing of personal data
We process personal data of our users only to the extent necessary to provide a functional website and our content and services. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.
2. legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 (1) lit. a EU Data Protection Regulation (GDPR) serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 (1) lit. c GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f GDPR serves as the legal basis for the processing.
3. data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may take place beyond this if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
IV. Provision of the website and creation of log files
1. Description and scope of data processing
Each time our website is called up, our system automatically collects data and information from the computer system of the calling computer.
The following data is collected:
(1) Information about the browser type and version used
(2) The user’s operating system
(3) The user’s Internet service provider
(4) The user’s IP address
(5) The date and time of access
(6) Websites from which the user’s system accesses our website
(7) Websites that are accessed by the user’s system via our website
The data is also stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.
1.1 Web hosting
This website is hosted by an external service provider (Mittwald CM Service GmbH & Co.KG). The hosting of this website takes place in Espelkamp, Germany. Personal data collected on this website is stored on the hoster’s servers. This may include IP addresses, contact requests, meta and communication data, website accesses and other data generated via a website. We have concluded an order processing agreement with the provider in accordance with the requirements of Art. 28 GDPR, in which we oblige him to protect the data of our customers and not to pass them on to third parties.
2. Legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 (1) lit. f GDPR.
3. purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session. In these purposes also lies our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.
4. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
1. Description and scope of data processing
The following data is stored and transmitted in the cookies:
(1) language settings
(2) log-in information.
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.
2. purpose of data processing
We require cookies for the following applications: shopping cart
(3) language settings
(4) log-in information The user data collected through technically necessary cookies are not used to create user profiles.
Cookies are stored on the user’s computer and transmitted to our site by the user.
VI. registration for bondholders
1. description and scope of data processing
The bondholder newsletter dispatch is based on the user’s registration on the website: On our website there is the possibility to subscribe to a bondholder newsletter.
When registering for the newsletter, the data from the input mask is transmitted to us.
(1) Salutation, first and last name
(4) Postal contact details
(5) E-mail address
(6) Bond – information
(7) Nominal amount
(8) Proof/deposit statement
For the processing of the data, your consent is obtained during the registration process and reference is made to this data protection declaration.
No data will be passed on to third parties in connection with the processing of data for the dispatch of newsletters. The data is used exclusively for sending the newsletter.
2. legal basis for data processing
The Bondholder Newsletter dispatch takes place on the basis of the user’s registration on the website: The legal basis for the processing of the data after the user has registered for the newsletter is Art. 6 (1) lit. a GDPR if the user has given his consent.
3. purpose of data processing
The collection of the user’s e-mail address serves to deliver the bondholder newsletter.
The newsletter is sent on the basis of the user’s registration on the website: The collection of other personal data as part of the registration process serves to prevent misuse of the services or the e-mail address used.
4 Duration of storage
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Accordingly, the user’s data will be stored as long as the subscription to the Bondholder Newsletter is active.
The subscription to the Bondholder Newsletter can be cancelled by the user concerned at any time. For this purpose, a corresponding link can be found in each newsletter.
The newsletter is sent on the basis of the user’s registration on the website: This also enables revocation of consent to the storage of personal data collected during the registration process.
6. Google Analytics
Our website uses Google Analytics, an internet analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses so-called “cookies”.
Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, and compiling reports on website activity. Google will also use this information to provide the website operator with other services related to the use of the website and the Internet. The IP address sent by your browser as part of Google Analytics is not combined with other data from Google. The processing is carried out in accordance with Art. 6 para. 1 lit. a GDPR on the basis of the consent given by you. We use Google Analytics only with IP anonymisation enabled.
This means that your IP address is only processed further by Google in a shortened form. We have concluded an order processing agreement with the service provider in which we oblige it to protect our customers’ data and not to pass it on to third parties. Since a transfer of personal data to the USA takes place, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46 (2) lit. c GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavor to obtain additional regulations and commitments from the recipient in the USA.
However, we would like to point out that in this case you may not be able to use all functions of this website without restrictions. You can also prevent Google from collecting the data generated by the cookie and from analysing your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=de.
7. Google Web Fonts
We use “Google Web Fonts” on our website, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as: “Google”). Google Web Fonts enables us to use external fonts, so-called Google Fonts. For this purpose, the required Google Fonts are loaded into your browser cache by your web browser when you access our website. This is necessary so that your browser can also display a visually improved representation of our texts. If your browser does not support this function, a standard font will be used by your computer for display. The integration of these web fonts is done by a server call, usually a Google server in the USA. This transmits to the server which page of our website you have visited. Also, the IP address of the browser of the end device of the visitor is stored by Google.
We use Google Web Fonts for optimisation purposes, in particular to improve the use of our website for you and to make its design more user-friendly.
This is also our legitimate interest according to Art. 6 para. 1 lit. f GDPR. Google has submitted to the Privacy Shield Agreement concluded between the European Union and the USA and has certified itself. Google thereby undertakes to comply with the standards and regulations of European data protection law. You can find more detailed information in the entry linked below: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active Information from the third-party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 100
You can find more information on data protection in Google’s data protection declaration: http://www.google.de/intl/de/policies/privacy Further information on Google Web Fonts can be found at http://www.google.com/webfonts/, https://developers.google.com/fonts/faq?hl=de-DE&csw=1 and https://www.google.com/fonts#AboutPlace:about.
VII. e-mail contact
1. description and scope of data processing
It is possible to contact us at any time via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.
In this context, the data will not be passed on to third parties. Third parties.
The data is used exclusively for processing the conversation. The specification of an e-mail address is required for contact information, the specification of your name for personal salutation.
2. legal basis for data processing
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.
3. purpose of data processing
In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
4. duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For personal data sent by e-mail, the data will be deleted when the respective conversation with the user has ended. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified. The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. All personal data stored in the course of contacting us will be deleted in this case.
VIII. Use of Google Maps
IX. Data transfer and recipients
There will be no transfer of your personal data to third parties, unless
- we have explicitly indicated this in the description of the respective data processing.
- If you have given your express consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR,
- the transfer in accordance with Art. 6 para. 1 p. 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
- in the event that a legal obligation exists for the disclosure pursuant to Art. 6 para. 1 p. 1 lit. c GDPR and
- insofar as this is necessary pursuant to Art. 6 para. 1 p. 1 lit. b GDPR for the processing of contractual relationships with you.
We also use external service providers for the processing of our services, which we have carefully selected, commissioned in writing and with whom we have concluded order processing agreements pursuant to Art. 28 GDPR, if necessary. They are bound by our instructions and are regularly monitored by us. These are service providers for web hosting, sending emails and maintenance and care of our IT systems, etc. The service providers will not share this data with third parties.
X. Rights of the data subject
The following list includes all rights of data subjects under the GDPR. Rights that have no relevance to our own website do not need to be mentioned. In this respect, the listing can be shortened. If personal data is processed by you, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
1. Right of access
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing is taking place, you may request information from the controller about:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or the categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information on the origin of the data if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
2. right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
3. Right to restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims; or
(4) if you object to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller outweigh your grounds.
If the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. Right to erasure
a) Obligation to erase
You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay, if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
(4) The personal data concerning you have been processed unlawfully.
(5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, those personal data.
The right to erasure does not exist insofar as processing is necessary
(1) for the exercise of the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) of the GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) of the GDPR, insofar as the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
(5) for the establishment, exercise or defense of legal claims.
5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right against the controller to be informed about these recipients.
6. right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
(1) the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and
(2) the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
8. right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. Automated decision in individual cases including profiling
You have the right not to be subject to a decision based exclusively on automated processing – including profiling – which produces legal effects vis-à-vis you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted by Union or Member State law to which the controller is subject and that law contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
(3) is made with your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests. With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the following