Privacy

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the websites, features and content associated with it. (collectively referred to as “online offer”). With regard to the terminology used, e.g. “Personal data” or their “processing”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Tungsten Capital Management GmbH

Hochstraße 35-37

D-60313 Frankfurt

Management: Henning von Issendorff, Lutz Klaus

 

Data Protection Officer

Mathias Lechner

datenschutz@tungsten-funds.com

1.Collection and processing of personal data

When visiting the website, every access and every retrieval of a file stored on the website is logged. The following are logged: name of the retrieved file, date and time of the retrieval, amount of data transferred, message about successful retrieval, web browser and requesting domain. In addition, the IP addresses of the requesting computers are logged anonymously. The logging is done for the purpose of ensuring a smooth connection setup, an optimization of our websites and to ensure system stability. The data will not be used to draw any further conclusions about you. If you register for our newsletter online, we will explicitly ask you to agree that we may use your e-mail address for regular newsletter mailing. After registration, you will receive an initial e-mail with a link confirming your e-mail address. With each following newsletter you have the possibility, via an appropriate link, to unsubscribe from this newsletter.The storage of the data takes place in all cases only and as long as it requires the legal storage obligations and periods or the mentioned purposes are present. After that they will be deleted.

2.Transmission of data

A transfer of personal data to third parties is intended only for specific purposes. These purposes are based on the existence of legal regulations, e.g. GwG, the fulfillment of contractual agreements and your consent as well as the follow-up of legal claims in so far as this does not preclude legitimate interests of third parties.The data transfers resulting from the use of cookies, analysis tools and newsletters can be found in the information under 3., 4. and 5.

3. Cookies and range measurement

Cookies are information transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage. We use temporary and permanent cookies. In part, the cookies are used for security or are necessary for the operation of our online offer. In addition, we or our technology partners use cookies for the pseudonymous range measurement. If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer. Also the web analytics service Google Analytics. (Inc., 1600 Amphitheater Parkway Mountain View, CA 94043, USA) uses cookies. These text files are stored on your computer and allow an analysis of the use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. For more information on how to handle user data on Google Analytics, please refer to the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=en You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available under the following link and install: https://tools.google.com/dlpage/gaoptout?hl=de In addition, you can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie is set to prevent your data from being collected on future visits to this website: Click here to be excluded from the Google Analytics measurement.

4. Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), Google Analytics uses a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https: // tools .google.com / dlpage / gaoptout? hl = en. For more information about Google’s data usage, hiring and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or apps Our Partners “), https://policies.google.com/technologies/ads (” Advertising Use of Data “), https://adssettings.google.com/authenticated (” Managing information Google uses to show you advertising “).

5th NewsletterWith the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletters contain information about our products, offers, promotions and our company. Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged. Shipping Service Provider: The newsletter is distributed via “MailChimp”, a mailing list platform of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA. The privacy policy of the shipping service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). Furthermore, the shipping service provider may, according to its own information, transmit these data in pseudonymous form, i. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for statistical purposes, to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write them down or to pass them on to third parties. Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

The dispatch of the newsletter and the success measurement are made on the basis of a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission according to Art. § 7 Abs. 3 UWG. The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to the receipt of the newsletter. Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. If the users have only subscribed to the newsletter and terminated this registration, their personal data will be deleted.

6. Integration of services and content of third parties

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Services, such as Incorporate fonts (hereafter referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer. The following presentation provides an overview of third-party providers as well as their contents, as well as links to their data protection statements, which contain further information on the processing of data and, for already mentioned here, contradictory possibilities (so-called opt-out) contain:

– External fonts from Google, LLC., Https://www.google.com/fonts (“Google Fonts”). The integration of Google fonts is done by a server call on Google (usually in the US). Privacy Policy: https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated

7. Right of information and appeal

At any time you have the right to free information about your stored personal data, their origin and recipient and the purpose of the data processing and a right to correct, block or delete this data. A deletion can only be made if there are no legal or contractual obligations to collect the data. If data has been collected due to a legitimate interest, you have the option of objecting to the processing. You can contact the data protection officer at any time for further information on personal data. In addition, you have the right to complain to the relevant supervisory authorities