Legacy Policies

For us, Whatforextotradetoday.com AG, the protection of your privacy is an important concern. With the following information we would like to inform you about the type, scope and purpose of the collection and use of personal data.

The data protection declaration (including legally required information content) is divided into two parts:
Part 1: Information on data protection regarding our data processing
Part 2: Supplementary privacy policy for our website
Part 3: Information on data protection for applicants
Part 1: Information on data protection

Information on data protection regarding our data processing in accordance with articles (art.) 13, 14 and 21 of the Data Protection Act. We take data protection seriously and hereby inform you how we process your data and which claims and rights you are entitled to according to the data protection regulations. Valid from 25 May 2018.
1. entity responsible for data processing and contact data responsible for data protection law

Whatforextotradetoday.com

and its subsidiaries.

In exceptional cases, there may also be a « joint and several responsibility » with other third parties. Currently, this is limited to individual constellations in the area of property and facility management.

2. purposes and legal basis on which we process your data

We process personal data in accordance with the provisions of the Basic Data Protection Regulation (DSGVO), the Federal Data Protection Act (BDSG) and other applicable data protection regulations (details below). Which data is processed in detail and how it is used depends largely on the services requested or agreed upon in each case. Further details or additions to the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provided to you (e.g. in the context of the use of our website or our terms and conditions). Furthermore, this data protection information may be updated from time to time.

2.1 Purposes for fulfilling a contract or pre-contractual measures (Art. 6 para. 1 b DSGVO)

The processing of personal data is carried out to execute our contracts with you and the execution of your orders as well as to carry out measures and activities within the framework of pre-contractual relations, e.g. with interested parties. In particular, the processing serves to provide services in accordance with your orders and wishes and includes the services, measures and activities necessary for this purpose. This includes all business activities with a focus on real estate (especially acquisition, sale, brokerage, leasing and administration) and investments in real estate (funds and direct investments). This essentially includes contract-related communication with you, the verifiability of transactions, orders and other agreements as well as quality control through appropriate documentation, goodwill procedures, measures for the management and optimization of business processes as well as the fulfillment of general duties of care, management and control by affiliated companies (e.g. parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax evaluation of operational services, risk management, assertion of legal claims and defense in legal disputes; ensuring IT security (and the ability to handle the data in the event of legal disputes); and Guaranteeing IT security (including system and plausibility tests) and general security, including building and plant security, securing and exercising building rights (e.g. through access controls); guaranteeing the integrity, authenticity and availability of data, preventing and solving criminal offences; monitoring by supervisory bodies or control authorities (e.g. auditing).

2.2 Purposes within the scope of a legitimate interest of us or third parties (Art. 6 para. 1 f DSGVO)

Beyond the actual fulfillment of the contract or preliminary contract, we may process your data if necessary to protect legitimate interests of us or third parties, in particular for purposes

advertising or market and opinion research, provided you have not objected to the use of your data
the obtaining of information and data exchange with credit agencies, insofar as this exceeds our economic risk
the testing and optimization of procedures for requirements analysis
the further development of services and products as well as existing systems and processes
the disclosure of personal data as part of due diligence in the course of company sales negotiations
for comparison with European and international anti-terrorism lists, insofar as they go beyond the legal obligations
the enrichment of our data, including the use or research of publicly available data
statistical evaluations or market analysis
of benchmarking
the assertion of legal claims and defence in legal disputes that are not directly attributable to the contractual relationship
the limited storage of the data, if deletion is not possible or only possible with disproportionately high expenditure due to the special type of storage
the development of scoring systems or automated decision-making processes
the prevention and clarification of criminal offences, insofar as not exclusively for the fulfilment of legal requirements
building and plant security (e.g. through access controls and video surveillance), insofar as this goes beyond the general duty of care
internal and external investigations, security audits
the possible listening or recording of telephone conversations for quality control and training purposes
obtaining and maintaining certifications of a private or governmental nature
securing and exercising the householder’s rights by means of appropriate measures as well as video surveillance to protect our customers and employees and to secure evidence in the event of criminal offences and their prevention, and
the involvement of service providers as independent or joint responsible parties to carry out activities for the fulfilment of a contract or pre-contractual measures (cf. clause 2.2) or for the fulfilment of a legitimate interest as listed above.

2.3 Purposes within the scope of your consent (Art. 6 para. 1 a DSGVO)

A processing of your personal data for specific purposes (e.g. use of your e-mail address for marketing purposes) can also take place on the basis of your consent. As a rule, you can revoke your consent at any time. This also applies to the revocation of declarations of consent that were issued to us prior to the validity of the DSGVO, i.e. before 25 May 2018. You will be informed separately about the purposes and consequences of revocation or failure to grant consent in the corresponding text of the consent.

As a general rule, the revocation of a consent is only effective for the future. Processing that took place before the revocation is not affected and remains lawful.
2.4 Purposes to meet legal requirements (Art. 6 para. 1 c DSGVO) or in the public interest (Art. 6 para. 1 e DSGVO)

Like everyone who is involved in the business world, we are also subject to a variety of legal obligations. Primarily these are legal requirements (e.g. commercial and tax laws), but also, where applicable, regulatory or other official requirements. The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and clarification of terrorist financing and asset-endangering criminal offences, comparisons with European and international anti-terrorist lists, the fulfilment of tax law control and reporting obligations and the archiving of data for data protection and data security purposes as well as audits by tax authorities and other offices. In addition, the disclosure of personal data may become necessary within the scope of official/judicial measures for the purpose of gathering evidence, criminal prosecution or enforcement of civil law claims.
3. the categories of data processed by us, if we do not receive data directly from you, and their origin

As far as this is necessary for the provision of our services, we process personal data permissibly received from other companies or other third parties (e.g. credit agencies, address publishers, property and facility management). In addition, we process personal data that we have permissibly taken, received or acquired from publicly accessible sources (such as telephone directories, commercial and association registers, registration registers, debtor registers, land registers, press, Internet and other media) and may process them.

Relevant categories of personal data may include in particular

Personal data (name, date of birth, place of birth, nationality, marital status, profession/industry and comparable data)
Contact details (address, e-mail address, telephone number and similar data)
Address data (registration data and comparable data)
Payment/confirmation of cover for bank and credit cards
Information about your financial situation (creditworthiness data including scoring, i.e. data for assessing the economic risk)
customer history
Data on your use of the telemedia offered by us (e.g. time of access to our websites, apps or newsletters, pages/links clicked on by us or entries and comparable data)
Video data

4. recipients or categories of recipients of your data

Within our company, those internal departments or organizational units receive your data that require it to fulfill our contractual and legal obligations or in the context of processing and implementing our legitimate interests. Your data will only be passed on to external parties

in connection with the contract execution
for the purpose of fulfilling legal requirements according to which we are obliged to provide information, report or pass on data or if the passing on of data is in the public interest (see section 2.4)
insofar as external service providers process data on our behalf as contract processors or function providers (e.g. external computer centers, support/maintenance of IT/IT applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data validation or -plausibility checks, data destruction, purchasing/procurement, customer management, lettershops, marketing, media technology, research, risk controlling, accounting, telephony, website management, property and facility management, auditing services, credit institutions, printing companies or companies for data disposal, courier services, logistics)
on the basis of our legitimate interest or the legitimate interest of the third party for the purposes mentioned in section 2.2 (e.g. to authorities, credit agencies, collection agencies, lawyers, courts, creditors, companies belonging to the Group and committees and supervisory bodies)
if you have given us permission to transfer your data to third parties.

We will not pass on your data to third parties beyond this. If we commission service providers within the scope of order processing, your data is subject to the same security standards there as with us. In all other cases, the recipients may only use the data for the purposes for which they were transmitted.
5. duration of the storage of your data

We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.

If the data are no longer required for the fulfilment of contractual or legal obligations and rights, they will be regularly deleted, unless their – temporary – further processing is necessary to fulfil the purposes listed under item 2.2 out of an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if deletion is not possible or only possible at disproportionately high expense due to the special type of storage and processing for other purposes is excluded by suitable technical and organizational measures.
6. processing of your data in a third country or by an international organization

Data will be transferred to countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) if it is necessary to execute an order/contract from or with you, if it is required by law (e.g. tax reporting obligations), if it is in the scope of a legitimate interest of us or a third party or if you have given us your consent.

The processing of your data in a third country may also be carried out in connection with the involvement of service providers (e.g. in the context of order processing). Unless the EU Commission has decided on an adequate level of data protection in the country in question, we will ensure that your rights and freedoms are adequately protected and guaranteed in accordance with EU data protection regulations by means of appropriate agreements. We will provide you with the corresponding detailed information on request.

Information on suitable or appropriate guarantees and on the possibility of obtaining a copy from you can be obtained on request from the company data protection officer.
7. your data protection rights

Under certain conditions you can assert your data protection rights against us

Thus, you have the right to receive information from us about your data stored with us according to the rules of Art. 15 DSGVO (if necessary with restrictions according to § 34 BDSG).
Upon your request, we will correct the data stored about you in accordance with Art. 16 DSGVO if it is incorrect or inaccurate.
If you wish, we will delete your data in accordance with the principles of Art. 17 DSGVO, provided that other legal regulations (e.g. legal storage obligations or the restrictions according to § 35 BDSG) or an overriding interest on our part (e.g. to defend our rights and claims) do not conflict with this.
Taking into account the requirements of Art. 18 DSGVO, you can demand that we restrict the processing of your data.
Furthermore, you may object to the processing of your data in accordance with Art. 21 DSGVO, on the basis of which we must stop processing your data. However, this right of objection only applies if there are very special circumstances in your personal situation, whereby our company’s rights may conflict with your right of objection.
You also have the right to receive your data in a structured, common and machine-readable format under the conditions of Art. 20 DSGVO or to transfer it to a third party.
In addition, you have the right to revoke your consent to the processing of personal data at any time with effect for the future (see section 2.3).
Furthermore, you have the right of appeal to a data protection supervisory authority (Art. 77 DSGVO). However, we recommend that you always address a complaint to our data protection officer first.

If possible, your requests to exercise your rights should be addressed in writing to the above address or directly to our data protection officer.

You are also entitled to the aforementioned rights if we process personal data within the scope of joint responsibility with a third party in accordance with Art. 26 DSGVO. This is currently limited to individual constellations in the field of property and facility management. Insofar as you interact with a property or facility manager commissioned by us and we have concluded a contract with this manager on joint responsibility, it is agreed that the parties must fulfil their obligations under data protection law in accordance with their respective responsibilities for the individual process stages. It is regulated that the property/facility manager is available as the primary contact point for the rights to which you are entitled under the DSGVO. Based on the contractual agreements made in these cases, the contractual partners support each other mutually in order to comprehensively guarantee your data protection rights.

8. scope of your obligations to provide us with your data

You only need to provide us with the data that is necessary for the establishment and execution of a business relationship or for a pre-contractual relationship with us or that we are legally obliged to collect. Without this data we will usually not be able to conclude or execute the contract. This may also refer to data required later within the scope of the business relationship. If we request additional data from you, you will be informed separately of the voluntary nature of the information.
9. existence of an automated decision-making process in individual cases (including profiling)

We do not use purely automated decision-making procedures in accordance with Article 22 DSGVO. If we do use such a procedure in individual cases in the future, we will inform you of this separately if this is required by law.

Under certain circumstances, we may process your data partly with the aim of evaluating certain personal aspects (profiling).

In order to be able to inform and advise you about products in a targeted manner, we may use evaluation tools. These enable us to design products, communication and advertising, including market and opinion research, in line with your needs.

Such methods can also be used to assess your creditworthiness and solvency as well as to combat money laundering and fraud. So-called « score values » can be used to assess your creditworthiness and solvency. Scoring involves calculating the probability using mathematical procedures with which a customer will meet his payment obligations in accordance with the contract. Such score values thus support us, for example, in the assessment of creditworthiness, decision-making in the context of product deals and are incorporated into our risk management. The calculation is based on mathematically-statistically recognized and proven procedures and is carried out on the basis of your data, in particular income, expenses, existing liabilities, occupation, employer, length of employment, experience from the previous business relationship, contractual repayment of previous loans and information from credit agencies.

Information on nationality as well as special categories of personal data according to Art. 9 DSGVO are not processed.
Information about your right of objection Art. 21 DSGVO

1. you have the right to object at any time to the processing of your data, which is carried out on the basis of Art. 6 para. 1 f DSGVO (data processing on the basis of a balancing of interests) or Art. 6 para. 1 e DSGVO (data processing in the public interest), if there are reasons for doing so that arise from your particular situation This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO. If you lodge an objection, we will no longer process your personal data unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

2. we may also process your personal data in order to carry out direct advertising. If you do not wish to receive advertising, you have the right to object to this at any time; this also applies to profiling, insofar as it is connected with such direct advertising. We will take this objection into account for the future.

We will no longer process your data for the purposes of direct advertising if you object to the processing for these purposes. The objection can be made in any form and should be addressed to

Whatforextotradetoday.com AG

and its subsidiaries.

Our privacy policy as well as the information on data protection about our data processing in accordance with article (art.) 13, 14 and 21 DSGVO may change from time to time. We will publish all changes on this page.

Part 2: Supplementary data protection declaration for our website

1. body responsible

Whatforextotradetoday.com AG and its subsidiaries are responsible for data collection, data processing and data use in connection with the use of our website.

2. general information

The use of our website does not require prior registration, except in the institutional login area. When you visit our website, we collect and process the information that you send us in a technically automated manner (see section 3) and/or personal data (see section 4).

3. usage data

When you visit our website or use our services, the device you use and your Internet browser with which you access our website automatically transmits log data to our server. This log data includes in particular the name of the file called up (website), the amount of data transferred, the type and version of the web browser used, the operating system used (type and version), the date and time the page was called up, the referrer URL (website from which you accessed our website via a link) and the IP address of the computer making the request. After the IP address is no longer technically necessary for calling up the Internet offer, it is only stored in an abbreviated (anonymized) form for static evaluation.

The above automatically transmitted data is recorded and evaluated exclusively for the purpose of the correct and optimal presentation of the information offered and for statistical analysis. It is not possible for us to assign the data automatically transmitted to the server to specific natural persons, i.e. it is not possible to identify you directly on the basis of the automatically transmitted data. However, we would like to point out that it is theoretically possible, with the cooperation of your Internet access provider and over a certain period of time, to determine the owner of the Internet connection through which you access our site by means of the transmitted IP address. Your Internet access provider will inform you about the duration of the storage of used and assigned IP addresses with the Internet access provider.

4. type, scope and purpose of the collection and use of personal data

We collect, process and use personal data such as name, address, telephone number or e-mail address on these websites only for the purpose of contract implementation and to protect our own legitimate business interests with regard to the consultation and support of our clients. Otherwise, we use your voluntarily provided data exclusively for the purpose for which you have given them to us. Only if you have also given us your consent for use in the context of further offers or for marketing purposes will we also use your data for these purposes. Your personal data will be deleted as soon as their knowledge is no longer necessary for the purpose of storage, at the latest, however, after the complete execution of the contract and expiration of the tax and commercial law regulations.

a) Contact form
You have the possibility to contact us using the e-mail address provided. The provision of your personal data there is of course voluntary. The personal data provided by you in this context will be used exclusively for processing your inquiry, unless you have given your separate consent to any other use. If you use our contact form in the shareholders’ section to contact us, the data entered will be transmitted from your PC in encrypted form according to the latest technical standard (SSL) to protect it against misuse by third parties.

b) Passing on to third parties
Personal data transmitted to third parties when using our website will only be passed on to third parties in accordance with the strict requirements of the Federal Data Protection Act, namely if you have previously consented to the passing on of the data, if we are entitled to do so by law and/or are obliged to pass on the data by law, regulation, official or court order. In general, the data will not be passed on to third parties for the purpose of advertising.

c) Information, correction, blocking, deletion
You have the right to request information from us free of charge about the personal data stored about you, the recipients or categories of recipients to whom this data is passed on and the purpose of the storage. In addition, you may have the right to correct, block or delete personal data in accordance with legal requirements. Contact information can be found in our imprint.

5. cookies, tracking tools, social plugins

a) Cookies
Our site uses so-called « cookies », e.g. for user analysis, storage of the selected language or for an improved user experience. Cookies are small text files that are stored on your computer for the duration of a browser session. After the end of the browser session, the cookies we use are deleted again (so-called session cookies). These simplify and accelerate the control of your visit to our website. If you do not want our website to use cookies on your computer, you can deactivate cookies in your browser settings and select the browser setting so that you are informed when cookies are used on a website. However, we would like to point out that this may mean that the functions of our website can no longer be used to their full extent. You can find more information about this, for example, here and here.

This website also uses cookies for dialogue support. In the case of certain dialogs, which are built up over several pages, it is essential to use this tool for a meaningful process, as this is the only way to ensure that it is possible to scroll backwards in the current process. These cookies are automatically deleted by the Internet user’s PC when he or she leaves this website. Therefore, the use of cookies for dialogue support is in your interest.

We also use a cookie as part of our disclaimer for calling up protected pages of our website (e.g. on the web pages relating to real estate funds). Once you have confirmed the disclaimer by selecting the checkbox and clicking on the « Confirm » button, the cookie is set and enables you to navigate within protected pages. This cookie is automatically deleted after closing the browser window.

b) Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (« Google »), to analyse and regularly improve the use of this website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield.

The legal basis for the use of Google Analytics based on our legitimate interests (in the analysis, optimization and economic operation of our website) is Art. 6 para. 1 p. 1 lit. f DSGVO.

Google Analytics uses so-called « cookies », text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.

However, by activating IP anonymization on this website, your IP address will be shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area before. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.

The IP address transmitted by your browser within the scope of Google Analytics is not combined with other data from Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing this browser plugin.

The personal or pseudonymous data will be deleted or made anonymous after 14 months.

Further details and information can be found in Google’s data protection information and here as well as in the settings for the display of Google’s advertising displays.

Information about Google DoubleClick:

We use the services of Google DoubleClick or Google Ads to display or distribute online advertising. These services are provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (« Google »). Google DoubleClick recognizes your visit to our website and may provide you with online advertising on other websites for our offers. You can find an opt-out option at https://adssettings.google.de.

Information about Google Tag Manager:

Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate e.g. Google Analytics and other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, we refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

c) Heatmap

This website uses heatmap.me, a web analysis tool from HeatMap, Inc. 6724 Monroe Ave, Eldersburg, MD 21784, USA. This tool records interactions of randomly selected individual visitors with the website in an anonymous form. The result is a log of e.g. mouse clicks and use of individual page elements (no keyboard activity) with the aim of showing optimization possibilities for this website. In addition, information on the operating system and browser, as well as resolution and type of device, references to domains, geographical location, pages visited and date and time at which the website was accessed are recorded for statistical purposes.

This information is not personal and will not be disclosed by heatmap.me to third parties. The sole purpose of collecting your navigation information is to improve your experience when using our websites and web services. If you do not wish to have this recording, you can disable it by setting the do-not-track header in your browser. For more information, please visit the following page: https://heatmap.me/privacy

d) Social Plugins

Our website uses plugins of social networks (Twitter, Facebook etc.). Each time you call up a website of our internet presence that is equipped with such a plugin, the plugin causes the browser you are using to load and display the visual representation of the plugin from the server of the social network. In doing so, the social network server is informed which particular website of our Internet presence you are currently visiting and other data such as your IP address is transmitted.

In order to guarantee an appropriate data protection standard of our website, we have deactivated the plugins by using the corresponding buttons and have placed a short data protection notice in front of them.

We have no influence on the amount of data that the social network collects with the help of this plugin. Please refer to the privacy policy of the respective social network:

Facebook
LinkedIn
Twitter
YouTube

If you are not satisfied with the data protection measures described here or if you have any questions regarding the collection, processing and/or use of your personal data, we would be pleased to hear from you. We will try to answer your questions as soon as possible and implement your suggestions. Please contact us at contact(at)Whatforextotradetoday.com(at).com.

e) LinkedIn Insight Tag

This website uses the conversion tool « LinkedIn Insight Tag » from LinkedIn Ireland Unlimited Company. This tool creates a cookie in your web browser that allows the following information to be collected, among other things: referrer URL, IP address, device and browser characteristics and page events (e.g., page views), LinkedIn demographic information if the user is an active LinkedIn member, and timestamps. IP addresses are truncated or (if used to reach members across devices) hashed.

This technology allows us to generate reports on the performance of our advertisements and information on website interaction. To do this, the LinkedIn Insight tag is embedded in this website, which connects to the LinkedIn server when you visit this website and are logged into your LinkedIn account.

We process the data to evaluate campaigns and collect information about website visitors who may have reached us through our campaigns on LinkedIn. The legal basis of the processing is, art. 6 par. 1 sent. 1 lit. a. DSGVO.

The direct identifiers of members will be removed within seven days in order to pseudonymize the data. These remaining pseudonymized data will then be deleted after 180 days, unless you have already revoked your consent beforehand.

For more information, please read the LinkedIn Privacy Policy and the LinkedIn Opt-Out. LinkedIn members can control the use of their personal information for promotional purposes in their account settings.

6. scope of the privacy policy

This data protection declaration applies to all websites and services or offers for which Whatforextotradetoday.com AG and its subsidiaries are responsible. This data protection declaration does not apply to services for which separate data protection declarations apply which do not include this data protection declaration, such as the pages for which efonds Solution AG is responsible.

In particular, our data protection declaration does not apply to services offered by other companies or persons or other websites linked to our services. Our privacy policy does not cover the handling of information by other companies or organizations that advertise our services and may use cookies, pixel tags and other technologies to provide and offer relevant ads.

If you call up an external website from our site (external link), the external provider may receive from your browser the information from which of our websites you came to him. The external provider is responsible for this data. We, like any other provider of internet pages, are not able to influence this process.
7. security

At Whatforextotradetoday.com both technical and organizational security measures are used to protect the data you have made available from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. If personal data is collected and processed, the information is transmitted in encrypted form to prevent misuse of the data by third parties. Our security measures are continuously revised in line with technological developments. Our employees are obliged to maintain confidentiality.
Part 3: Information on data protection for applicants

Information on data protection about our processing of applicant data in accordance with Articles (Art.) 13, 14 and 21 of the Basic Data Protection Regulation (DSGVO), here for PDF download.
Further Information

Your trust is important to us. If you have any questions which this data protection declaration could not answer or if you wish to receive more detailed information on any point, please contact our data protection officer at any time. In this context, we naturally also fulfill your standardized right to information.