1. Who are we?

Flossbach von Storch is one of the leading independent asset managers in Germany – and is still owner-operated by its founders and senior executives. You can find out more about us by reading our company portrait.

As a data controller pursuant to applicable data protection law, we

Flossbach von Storch SE,
Ottoplatz 1, 50679 Cologne, Germany
Tel.: +49 221 33 88 - 0
E-Mail: info@fvsag.com

represented by the Managing Directors

Dr. Bert Flossbach, Dr. Tobias Schafföner, Dr. Till Schmidt, Marcus Stollenwerk

take all measures under applicable data protection law necessary to protect your personal data.

Should you have any questions about this privacy statement, please contact our data protection officer:

2B Advice GmbH
Joseph-Schumpeter-Allee 25, 53227 Bonn, Germany
Tel.: +49 228 9261 65 - 120,
Fax: +49 228 9261 65 - 109
fvs@2B-Advice.com

2. Scope of application of the privacy statement

The processing of personal data as defined by the legislator refers to processes such as the collecting, recording, organising, arranging, storing, changing or modifying, selecting, querying, using, disclosing by transmission, dissemination or other form of provision, comparing or linking, restricting, deleting or destroying of personal data.

Personal data is all information related to an identified or identifiable natural person.

This privacy statement refers to the personal data of clients, prospective clients, applicants or visitors.

This privacy statement applies to our website www.flossbachvonstorch.de.

3. Collecting and processing of personal data

The following explains which data about you we collect and process and for what purposes. Your data will only ever be stored to the extent required by retention obligations and retention periods or for as long as the stated purposes apply.

3.1 Accessing the website

When visiting the website, accessing or viewing any of the files stored on the website this will be logged. This information is logged in order to pursue our legitimate interest (under Art. 6 (1) (f) of the General Data Protection Regulation (GDPR)) in guaranteeing a smooth connection and in optimising our websites and to ensure that the system is robust. The data will not be used to draw conclusions about you as an individual.

The following information will be logged:

• name of the accessed file,
• date and time of access,
• amount of data transferred,
• confirmation that the file has been accessed successfully,
• web browser and requesting domain,
• anonymised IP addresses of the device sending the request.

3.2 Requests for contact

the steps necessary to initiate a contract in response to your enquiry (Art. 6 (1) (b) or (f) of the GDPR). Typical purposes are responding to queries about our products in the areas of financial portfolio management, investment and acquisition brokerage and to give investment advice / initiate contact with clients and to conclude contracts / process applications / maintain business relationships.

The following data may be collected:

• Surname, first name and salutation
• Contact details
• Information which you share with us about your interests and wishes

3.3 Registering for the newsletter

When you register for our newsletter online, we will ask you to provide your explicit consent for us to use your email address to send our newsletter to you on a regular basis. Once you have registered, you will receive an initial email to confirm your email address.

You can revoke your consent with effect for the future at any time. You also have the right to object to your personal data being processed for marketing purposes at any time and free of charge.

The legitimacy with which your data has been processed until the point at which you revoke your consent will not be affected by this. With every subsequent newsletter, you have the option to use the corresponding link to unsubscribe from this newsletter.

Please note that our newsletter contains promotional content, as we use it to advertise our products and services. Your consent to the use of your email address is given on a completely voluntary basis and, should you not wish to give your consent, this will have no wider implications on other aspects of the business relationship.

The use of your email address to send our newsletter is based on your consent (Art. 6 (1) (a) of the GDPR).

3.4 Registering for private areas

There is an option to register for private areas of our website. If a user registers for private areas of our website, this is done on a voluntary basis for the purpose of direct communication and the execution of orders between the contractual parties.

As part of this process, your personal information will be processed in order to fulfil an agreement to which you are a party or to initiate additional agreements in accordance with the terms of use of the distributor portal (Art. 6 (1) (b) of the GDPR).

3.5 Registering for the Flossbach von Storch Postbox online platform

There is also an option to register for the Flossbach von Storch Postbox online platform. If a user registers with the Flossbach von Storch Postbox online platform, this will be on a voluntary basis for the purpose of securely sharing confidential documents, particularly the regular asset reports. When the portal is used, data of this kind is recorded to track error statuses guaranteeing comprehensive customer service when troubleshooting during the log-in process.

The following data ‒ and the following data only ‒ are stored for this purpose: 

• session data,
• system events.
• log-in data.

The processing of your personal data is necessary to safeguard the legitimate interests of Flossbach Storch and/or a third party (e.g. IT service providers or supervisory authorities) or to fulfil a contract to which you are a party or to initiate further contracts in accordance with the terms of use of the Postbox (Article 6(1)(b) and (f) of the General Data Protection Regulation).

3.6 Registering for teleconferences, web conferences and livestreams

We also offer the option of registering for teleconferences, web conferences and livestreams. Participation is on a voluntary basis for the purpose of communicating directly and holding conferences.

Your personal information will be processed to safeguard legitimate interests in the holding of conferences in the best possible way and to fulfil an agreement to which you are a party or to initiate additional agreements in accordance with the terms of use of the telephone and web conferences (Art. 6 (1) (b) and (f) of the GDPR).

3.6.1 GoToMeeting/LogMeIn

We use GoToMeeting/LogMeIn software for online meetings, video conference and web conferences. This may involve transferring data to the USA. The current standard EU contractual clauses have therefore been concluded with the provider in order to guarantee a suitable level of data protection.

The "LogMeIn International Privacy Policy" can be found at https://www.logmein.com/trust/privacy.

3.7 Cookies und Analysetools

Our Cookie Guideline provides information about how personal data is processed using cookies and similar technologies on our website [link].

3.8 Registration for the Flossbach von Storch Private Asset Management client portal

You also have the option of registering for the Flossbach von Storch Private Asset Management client portal. The client portal is based on the software-as-a-service application FinaDesk from the provider FinaSoft. This registration is voluntary and serves the protected exchange of confidential documents, particularly regular asset reports. In addition, you can view and display your portfolio managed by us. During use, data is recorded that is used to trace error statuses in order to ensure comprehensive customer service in terms of troubleshooting during the login process. 

Only the following data is stored for this purpose: 

• Session data
• System events 
• Login data 

Your personal data is processed to safeguard our legitimate interests in the use and further development of the customer portal and to fulfil a contract in which you are a contractual partner or to initiate further contracts in accordance with the terms of use (Article 6 (1) (b) and (f) of the General Data Protection Regulation).

3.9 Electronic signature services

We use Adobe Sign software from Adobe Systems Software Ireland Limited, 4-6 Riverwalk, City West Business Campus, Saggart D24, Dublin, Ireland ("AdobeSign") for the digital signature of contracts and documents. For this purpose, Adobe Sign processes the data entered by you when using the service, usage data from your end device and transaction-related data. The processing of your personal data by Adobe Sign takes place within the framework of GDPR. The legal basis is Art. 6 (1) (b) and (f) of the General Data Protection Regulation. Further information on data processing by Adobe Sign can be found in Adobe's data protection centre.

3.10 Use of Myra

We use the "Myra" tool from Myra Security GmbH to ensure a high level of security for our website and to protect our systems from unauthorised access. Myra helps us to protect our website against cyber-attacks and contributes to the stability and security of our IT infrastructure. As part of this use, data required for the functioning of the security system may be processed. This may include information such as IP addresses or other data collected as part of security protocols. Data processing is carried out based on our legitimate interest in securing our IT systems and the integrity of our website (Art. 6 (1) (f) GDPR). Further information on data protection and how Myra works can be found at: https://www.myrasecurity.com/en/privacy-policy/. 

4. Where we transfer your data to and why

4.1 Use of data within the company

Within Flossbach von Storch, only people in positions who need access to your personal data to fulfil our contractual or statutory obligations or to safeguard our legitimate interests will have access to it.

4.2 Use of data within the group of companies

In order to offer you the best possible level of service within the contractual relationship, we occasionally share data with Flossbach von Storch Invest SA, Luxembourg, Flossbach von Storch AG, Switzerland. As part of data processing subject to instructions on behalf of Flossbach von Storch SE, Germany, and Flossbach von Storch AG, Switzerland, we collect data which is recorded via the respective country websites. This data is then provided to the corresponding companies in order to pursue the stated purposes.

We thereby ensure that the applicable statutory data protection regulations are adhered to and that your personal data is protected to an appropriate extent at all times.

For this reason, we have taken corresponding measures with Flossbach von Storch Invest S.A., Luxembourg, and Flossbach von Storch AG, Switzerland, to ensure that data protection regulations are adhered to.

We have concluded corresponding agreements (data processing agreement) with the individual companies to ensure that the personal data shared within the Group always remains protected.

In accordance with these agreements and applicable data protection law, we will only share personal data with other companies in the group of companies for the purposes set out in this privacy statement.

In doing so, we support these companies both in their operations as well as with respect to their adherence to the technical and organisational measures which we also employ to ensure that your personal data is secure. Where possible, we use pseudonymisation and anonymisation measures to protect your data. An adequacy resolution of the EU Commission is in place with regard to the transfer of data to Switzerland to ensure that the personal data processed there is protected to the same extent as within the EEA.

4.3 Use of data outside of the company

We take the protection of your personal data very seriously and will only pass on information about you where statutory provisions require us to do so, when you have consented to this or in order to fulfil contractual obligations.

4.3.1 Disclosure due to a statutory obligation

For the following recipients, there may be a statutory obligation to disclose your personal data:

• public bodies or supervisory authorities such as the German Federal Financial Supervisory Authority (BaFin), tax authorities, customs authorities;
• judicial and law enforcement authorities such as the police, courts, public prosecutor;
• lawyers or notaries, such as in legal disputes;
• auditors.

4.3.2 Disclosure in order to fulfil an agreement

We collaborate with other companies to enable us to fulfil our contractual obligations. This includes:

• transportation service providers and hauliers;
• event organisers and training providers if you have registered with us for specific trade fairs or events;
• banks and financial service providers for handling all financial affairs.

4.3.3 Sharing data with our own service providers

In order to run our business efficiently, ensure that everything runs smoothly and improve our IT security, we use the services of external service providers which may receive personal information from you in order to fulfil the purposes described above, including

• IT service providers, particularly in the area of firewall/IT security, website hosting,
• Cloud providers,
• print and telecommunications service providers, particularly for sending publications or the newsletter by post,
• debt collection, consultancy or sales companies,
• service providers assisting with our Customer Relationship Management.

We have concluded corresponding subcontractor agreements to ensure that the service providers adhere to the same data protection standards as we do in-house. Some of the aspects governed by these agreements are as follows:

• third parties only have access to the data that they need to fulfil the tasks assigned to them;
• the only employees of the service providers who have access to your data are those who have explicitly undertaken to adhere to data protection regulations;
• the service providers adhere to technical and organisational measures which ensure that data is secure and protected;
• the servers on which data is processed for these purposes are hosted in the EU;
• what happens to the data when the business relationship between the service provider and us has come to an end.

With service providers based outside of the European Economic Area (EEA), we take special security measures (such as the use of special clauses to the agreement) to ensure that the data is handled with the same level of care as in the EEA. We audit all of our service providers on a regular basis to ensure that they are adhering to our specifications.

4.4 Sale of personal data

We will never sell your personal data to third parties!

5. Your rights

You have certain rights with regard to the processing of your personal data. More information can be found in the corresponding provisions of the General Data Protection Regulation (in Articles 15 to 21).

Please send corresponding orders to our email address datenschutzluxemburg@fvsag.com or contact us in other ways (see point 2 of this privacy statement for further contact details).

5.1 Right to information and rectification

You have the right to receive information from us concerning which of your personal data we are processing.

In the event that this information is not (or no longer) correct, you can demand that we rectify the data and that missing information be added.

5.2 Right to deletion

Under the following circumstances, you can demand that your personal data be immediately deleted:

• if your personal data is no longer required for the purposes for which they were collected;
• if you have revoked your consent and there are no other legal grounds for processing the data;
• if you revoke your consent to processing and there are no overriding legitimate reasons for processing the data;
• if your data is being processed on an illegitimate basis;
• if your personal data needs to be deleted in fulfilment of statutory obligations.

Please note that, before your data is deleted, we will need to check whether there is any legitimate reason for processing your personal data.

5.3 Right to restriction/blocking of processing

You can demand that the processing of your personal data be restricted for any of the following reasons:

• if you dispute the accuracy of the data until we have the chance to verify that the data is accurate;
• if the data is being processed unlawfully and you merely demand that the use of your personal data be restricted instead of deleted;
• if we no longer need your personal data for the purposes of processing, but you still require it for the purposes of asserting, exercising or defending legal claims;
• if you have objected to processing and it has not yet been verified whether your legitimate interests override ours.

5.4 Right to object

5.4.1   Case-by-case right to object

To the extent that processing is carried out in the public interest or on the basis of the balancing of interests, you have the right to object to processing on grounds relating to your particular situation. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing your data which override your interests, rights and freedoms or if your personal data is used to assert, exercise or defend legal claims. The objection shall not contradict the legitimacy with which your data was processed prior to the objection.

5.4.2   Objection to advertising

In cases in which your personal data is used for promotional purposes, you will be able to object to this form of processing at any time. We will then no longer process your personal information for these purposes.

5.5 Right to data portability

You have the right to receive the personal data that you have provided to us for the purposes of processing in a portable and machine-readable format upon request.

5.6 Right to lodge a complaint with a supervisory authority

We will always endeavour to process your queries and claims as quickly as possible in order to safeguard your rights accordingly. However, depending on the number of queries we receive, it may take up to 30 days before we can respond to your concerns. If there is a delay, we will inform you in a timely manner about the reasons for the delay and will discuss further steps with you.

In some cases, we may not be allowed or able to provide you with information. Where permitted by law, we will inform you of the reason why we are refusing to provide the information.

If you are still not satisfied with our answers and response or if you believe we are violating applicable data protection law, you have the right to lodge a complaint with our data protection officer and any supervisory authority within the European Union. The supervisory authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit
Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf

Telefon: 0211/38424-0
Fax: 0211/38424-10
E-Mail: poststelle@ldi.nrw.de
Webseite: www.ldi.nrw.de

6. Subject to change

Flossbach von Storch SE reserves the right to amend this privacy statement at any time in accordance with legal guidelines. We therefore recommend that you regularly visit our website to check our up-to-date data protection practices.

As of 15/10/2024

1. Cookies

Cookies of this kind help make a website usable by allowing for basic functions such as page navigation and access to secure areas (if these cookies are not set, a website will not work correctly).

The legal basis for setting essential cookies is Art. 6 (1) (f) of the General Data Protection Regulation (GDPR). You can see a detailed list of all cookies used by clicking on the "Change your consent" button at the bottom of the page.

1.1 Essential cookies

Solche Cookies helfen dabei eine Webseite nutzbar zu machen, indem sie Grundfunktionen wie Seitennavigation und Zugriff auf sichere Bereiche der Webseite ermöglichen (ohne das Setzen von diesen Cookies könnte eine Webseite eigentlich nicht richtig funktionieren).

Die Rechtsgrundlage für das Setzen von unbedingten erforderlichen Cookies ist Art. 6 Abs. 1 Buchstabe f der Datenschutz-Grundverordnung. Eine ausführliche Liste aller eingesetztes Cookies können Sie unter dem Button "Ihre Zustimmung ändern" am Ende der Seite anschauen.

1.2 Analysis cookies

These help the website operator to understand how visitors/users/participants interact with the website by collecting and reporting information in an anonymous format (such as for measuring the number of visitors or the average time spent on the website).

The legal basis for setting the analysis cookies is Art. 6 (1) (a) of the GDPR. You can see a detailed list of all cookies used by clicking on the "Change your consent" button at the bottom of the page.

1.3 Advertising cookies

Cookies of this kind are used to track visitors on websites. The intention is to show ads which are relevant and appropriate to the individual user and therefore more valuable to publishers and third-party advertisers.

The legal basis for setting advertising cookies is Art. 6 (1) (a) of the General Data Protection Regulation – GDPR. You can see a detailed list of all cookies used by clicking on the "Change your consent" button at the bottom of the page.

2. Analysis tools

The following provides you with information about the tools we use, the respective service providers and their data protection information, along with information about how to disable or block these tools.

2.1 Google Analytics

The web analysis service Google Analytics (Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA) also uses cookies.

These text files are stored on your computer and allow how the website is used to be analysed. The information generated by the cookie about your use of this website will be sent in an anonymous format to a Google server in the USA, where it will be stored. More information about how Google Analytics handles user data can be found in the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

You can stop cookies from being stored by adjusting your browser software accordingly; however, we need to tell you that if you do so, you might not be able to use all functions of this website to their full extent.

You can also stop Google from collecting data generated by the cookie and related to how you use the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

We have concluded a contract data processing agreement with Google and fully implement the most stringent requirements issued by the German data protection authorities when using Google Analytics.

We also want to point out the following points about Google Analytics to you:

• Google Analytics records the demographic profiles of website visitors in terms of age, gender and interests. The provider receives this data from its own personalised ads and third-party visitor data. However, it is not possible to link this data to specific individuals.
• Google Remarketing allows targeted advertising to be sent to users who have already shown an interest in our online services. Cookies are used as part of this process as well and can be disabled at www.google.com/settings/ads.
• Google AdWords Conversion Tracking sets a cookie when you access our online services via a Google ad. These cookies are valid for 30 days and are not used to identify users personally, but instead serve statistical purposes for improving our advertising activities. As every user receives a different cookie, no other AdWords customers can be tracked via the websites. You can stop this tracking by blocking the setting of cookies from the googleadservices.com domain in your browser.
• Google Tag Manager sets simple website tags instead of cookies. No personal data is collected as part of this process, but this tool can trigger other tags which may collect data not accessed by Google Tag Manager. More information can be found at https://policies.google.com/privacy?hl=en.

2.2 Facebook Remarketing

Facebook Remarketing can be used to track the reach of our Facebook ads.

With your consent, we do this by using the "tracking pixel" of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). This pixel is set when you click on one of our ads on Facebook. The data collected this way remains anonymous to us so that we are unable to identify you personally.

However, you should know that this data can be stored and processed by Facebook and linked to your Facebook account and used for their own promotional purposes. For more information about this, please refer to the Facebook privacy policy at https://www.facebook.com/about/privacy/.

By visiting https://www.facebook.com/ads/website_custom_audiences/ you can edit your settings and stop Facebook and its partners from placing ads.

The use of Facebook Remarketing is based on your consent in accordance with Art. 6 (1) (a) of the GDPR. The cookies used are explained further below or in the detailed overview of the cookie banner.

2.3 Microsoft Ads

Microsoft Ads also use the aforementioned pixels. This tool gives us the option to create remarketing lists based on the activities of users of our website.  More information about data protection and about the cookies used with Microsoft Bing can be found on the Microsoft website: https://privacy.microsoft.com/en-gb/privacystatement

The use of Microsoft Ads is based on your consent in accordance with Art. 6 (1) (a) of the GDPR. The cookies used are explained further below or in the detailed overview of the cookie banner.

2.4 Adform Tool

On this website we use the Adform tool from Adform A/S Wildersgade 10B, sal. 1 DK-1408 Copenhagen, Denmark, which collects data for analysis, marketing and optimisation purposes and therefore helps us to improve our marketing strategies, our website or app.

The data collected is used by Adform to link advertising contacts and clicks on ads with the resulting use of our website or app. This way we can determine whether Internet users who have seen our ads visit our website, which products they are interested in and also how the app is used. This helps us to use our advertising budget more efficiently. We can also use this data collected to deliver ads based on your interests (such as products viewed).

Pseudonymised online identification numbers (online ID) such as cookie IDs, IP address, device IDs, advertising ID/IDFA (such as on Android or Apple smartphones) are used to collect the data. No unique user-based data such as name or address are stored in this process. All IDs used by us are only used to identify your terminal, your Internet browser or the app used.

If you do not want your data to be collected by Adform, click on the following link for information about how you can stop data from being collected on your computer or mobile device:

https://site.adform.com/privacy-center/platform-privacy/opt-out/

The use of Adform Tool is based on your consent in accordance with Art. 6 (1) (a) of the GDPR. The cookies used are explained further below or in the detailed overview of the cookie banner.

2.5 Microsoft Clarity

We use Microsoft Clarity, a web-analytics service provided by Microsoft Corporation, to improve the user experience on our website. Microsoft Clarity enables us to analyse the behaviour of our visitors. This enables us to gain insights into the use of our website and make targeted improvements. Microsoft Clarity uses various tracking technologies, including cookies, to collect data on user behaviour.

This data may include information such as pages visited, time spent on the site, clicks and scrolling behaviour. The use of Microsoft Clarity is in accordance with your consent pursuant to Article 6(1)(a) GDPR. Before we place cookies or similar tracking technologies on your device, we ask for your express consent via the cookie banner. You can find an explanation of the cookies used below or in the detailed overview of the cookie banner.

For more information regarding Microsoft's data protection, please visit Microsoft's privacy policy.

The use of Microsoft Clarity is based on your consent in accordance with Art. 6 (1) (a) of the GDPR. The cookies used are explained further below or in the detailed overview of the cookie banner.

2.6 Microsoft Dynamics 365 Marketing

We use Microsoft Dynamics 365 Marketing to manage and optimise our marketing activities. Dynamics 365 Marketing enables us to create targeted marketing campaigns, track customer interactions and perform analyses to improve our marketing efforts. The data collected may include information about marketing campaigns, customer interactions and user behaviour.

The use of Microsoft Dynamics 365 Marketing is in accordance with your consent pursuant to Article 6(1)(a) GDPR. You can find an explanation of the cookies used below or in the detailed overview of the cookie banner.

For more information regarding Microsoft's data protection, please visit Microsoft's privacy policy.

2.7 Hotjar

We use Hotjar, a web analysis and feedback tool, to improve the user experience on our website. Hotjar enables us to analyse the behaviour of our visitors. This gives us insights into the use of our website.

Hotjar uses various technologies, including a cookie and tracking code, to collect data on user behaviour. This may include mouse movements, clicks, scrolling behaviour and pages visited.

The use of the Hotjar service is in accordance with your consent pursuant to Article 6(1)(a) GDPR. You can find an explanation of the cookies used below or in the detailed overview of the cookie banner.

Further information about Hotjar's data protection can be found in the Hotjar Privacy Policy.

2.8 Online service cituro

This site uses the cituro online service to offer you an online appointment booking service. When you open the online booking, your IP address and the time of access are recorded by the operator as part of technical logging and stored for two days. This information is not used for any other purpose.

When completing a booking, further personal data required for the provision of our services will be collected and processed. Further information can be found in the provider's privacy policy.

The use of cituro is based on your consent in accordance with Art. 6 (1) (a) of the GDPR. The cookies used are explained further below or in the detailed overview of the cookie banner.

2.9 Google Tag Manager

We use Google Tag Manager, a product of Google LLC, 1600 Amphitheater Parkway, Mountainview, California 94043, USA ("Google"). Google Tag Manager allows us to manage website tags via an interface. However, the Tag Manager itself, which uses the tags, works without cookies, and does not collect any personal data. The Tag Manager merely triggers other tags, which in turn may collect data. Corresponding explanations for these respective third-party providers can be found in this privacy policy. However, Google Tag Manager does not use this data. If you have set or otherwise deactivated cookies, this will be observed for all tracking tags used with Google Tag Manager, i.e. the tool will not change your cookie settings. Google may ask you for permission to share some product data (e.g. your account information) with other Google products to enable certain features, such as making it easier to add new conversion tracking tags for AdWords. In addition, Google's developers review product usage information from time-to-time to further optimise the product. However, Google will not pass on any data of this kind to other Google products without your consent.

The use of Google Tag Manager is in accordance with your consent pursuant to Article 6(1)(a) GDPR. We explain the cookies used below or in the detailed overview of the cookie banner.

Further information can be found in Google's terms of use for this product and in Google's privacy policy.

2.10 LinkedIn Ads Remarketing

We use the LinkedIn Remarketing service on our website if you have consented to marketing. The service provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland and, if applicable, LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085. We process the following data: IP address, browser type, date and time of visit, device information, device operating system, referrer URL, websites visited.

The interests of our website visitors are stored and we can place targeted adverts on other websites. Cookies or similar procedures may also be used. These are listed in the explanations of the consent banner.

Purpose: Targeted, interest-based advertising

Legal basis: Your consent

Data recipient: LinkedIn as our service provider and processor

Third country transfer: Information may be processed by LinkedIn in the USA for this purpose. The company offers suitable guarantees for an adequate level of data protection through the EU-U.S. Data Privacy Framework.

Further information can be found here:

Data protection information: https://www.linkedin.com/legal/privacy-policy

Cookie policy: https://www.linkedin.com/legal/cookie_policy

Contact the data protection officer: www.linkedin.com/help/linkedin/ask/TSO-DPO

2.11 Outbrain

We use the advertising service and advertising network Outbrain Inc, 111 West 19th Street, New York, NY 10011, USA. We process the following data: IP address, browser type, date and time of visit, device information, device operating system, referrer URL, websites visited.

The interests of our website visitors are stored and we can place targeted adverts on other websites. Cookies or similar procedures may also be used. These are listed in the explanations of the consent banner.

Purpose: Targeted, interest-based advertising

Legal basis: Your consent

Data recipient: Outbrain as our service provider and processor

Third country transfer: Information is processed for this purpose by Outbrain in the USA. The company offers suitable guarantees for an adequate level of data protection through the EU-U.S. Data Privacy Framework.

Further information can be found here:

Data protection information: https://www.outbrain.com/legal/privacy

Cookie policy: https://www.outbrain.com/legal/#cookies

Contact the data protection officer: dpo@outbrain.com

2.12 Taboola

We use the content recommendation network and advertising service Taboola Europe Limited, Aldgate House, 2nd Floor, 33 Aldgate High Street, London EC3N 1DL, UK. Data may also be processed by Taboola, Inc, 16 Madison Square West, 7th Floor, NY, New York. We process the following data: IP address, browser type, date and time of visit, device information, device operating system, referrer URL, websites visited.

The interests of our website visitors are stored and we can place targeted adverts on other websites. Tracking, cookies or similar procedures may also be used. These are listed in the explanations of the consent banner.

Purpose: Targeted, interest-based advertising

Legal basis: Your consent

Data recipient: Taboola as our service provider and processor

Third country transfer: Information may also be processed by Taboola in the USA for this purpose. The company does not yet participate in the EU-U.S. Data Privacy Framework. Appropriate guarantees for an adequate level of data protection are ensured by concluding the standard contractual clauses. Information on this: www.taboola.com/policies/media-privacy-addendum and here: https://www.taboola.com/policies/media-privacy-addendum/privacy-terms-for-advertisers.

Further information can be found here:

Data protection information: https://www.taboola.com/privacy-policy

Cookie policy: www.taboola.com/de/cookie-policy or www.taboola.com/policies/privacy-policy.

3. Social-Plugins – Soziale Medien

There is an option on our website to use social media buttons from the following companies:

Facebook Inc. (1601 S. California Ave - Palo Alto - CA 94304 – USA)

X Corp. (795 Folsom St. - Suite 600 - San Francisco - CA 94107 - USA)

XING AG (Gänsemarkt 43 - 20354 Hamburg - Germany)

LinkedIn Corporation (2029 Stierlin Court - Mountain View - CA 94043 - USA)

Shariff technology is used when implementing the buttons. As part of this process, the buttons are only embedded as an image, and the services of the aforementioned providers can only be accessed once the button has been activated. Prior to this, your data will be neither shared nor used with the social networks.

You can and should visit their homepages to find out all you need to know about the terms of use and data protection regulations of the social networks themselves. 

4. Push notifications

You can register to receive our push notifications. To send our push notifications, we use the "CleverPush" notification service operated by CleverPush UG (limited liability), Tondernstr. 1, 22049 Hamburg ("CleverPush").

Via our push notifications, you will receive regular current updates with our perspective on markets, money and financial policy and individual investment classes.

To register, you need to confirm your browser's request to send you notifications. This process is documented and stored by CleverPush. This includes storing the time of registration and your browser ID or your device ID. We need to collect your data so that, in the event of misuse, we will be able to understand what has happened, which will then help us to protect ourselves legally.

So that you can see the push notifications, CleverPush collects and processes your browser ID or, if accessed using a mobile device, your device ID on our behalf.

By subscribing to our push notifications, you confirm that you agree to receive them. The legal basis for your data being processed once you have registered for our push notifications is the consent you give pursuant to Art. 6 (1) (a) of the GDPR.

CleverPush also analyses the statistics relating to our push notifications. In this way, CleverPush can detect whether and when our push notifications are displayed and clicked on by you.

To access content (such as images) more quickly and to ward off attacks, CleverPush uses cloudfare.com services as part of the subcontractor agreement, products of Cloudflare, Inc., with which standard EU contractual clauses have been concluded.

CleverPush does not store any data containing personal data on Cloudflare servers, just general content such as text or images. When this content is accessed, the terminal you are using establishes a connection to Cloudflare, thereby processing the IP address of the terminal you are using.

You are able to revoke at any time for future effect your consent to your personal data being stored and used for the purposes of receiving our push notifications and to it being collected for the statistical purposes set out above.

To revoke your consent, you can change the settings for receiving push notifications in your browser.

If you are using our push notifications on a desktop PC with the Windows operating system, you can unsubscribe from our push notifications by right-clicking on the relevant push notification in the settings shown.

Your data will be deleted as soon as it is no longer needed to achieve the purposes for which it has been collected. Your data will therefore only be stored for as long as the subscription to our push notifications is active.

Click on the following link for details of the opt-out process: https://cleverpush.com/faq

You can also use the following link: https://www.flossbachvonstorch.de

4.1 Accessing the website

When you visit the website, every access and every retrieval of a file stored on the website is logged. Logging is carried out in pursuit of our legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) to ensure a smooth connection set-up, optimisation of our websites and to ensure system stability. The data is not used to draw any further conclusions about your person. 

The following are logged: 

Name of the retrieved file, 
Date and time of access, 
Amount of data transferred, 
Notification of successful retrieval, 
Web browser and requesting domain, 
Anonymised IP addresses of the requesting computers. 

4.2 Contact enquiries

If you contact us via the contact form, we ask you to provide personal details that are necessary to contact you personally. We process the data in order to enable communication that is tailored to the purpose of your enquiry and to take steps in response to your enquiry that are necessary to initiate a contract (Article 6 (1) (b) of the General Data Protection Regulation). Typical purposes include responding to enquiries about our financial portfolio management products, investment and contract brokerage and investment advice/initiating customer contacts and concluding contracts/processing applications/maintaining business relationships. 

The following data may be collected: 

Surname, first name and title 
Contact details 
Information about your interests and wishes that you communicate to us

4.3 Newsletter registration

When you register online for our newsletter, we will expressly ask for your consent so we can use your email address to send you the newsletter on a regular basis. After registering, you will receive an initial email with a link to confirm your email address. 

You can revoke your consent at any time in the future. You also have the right to object to the processing of personal data for marketing purposes at any time and free of charge. 

This does not affect the legality of data processing up to the point of cancellation. With each subsequent newsletter, you have the option to unsubscribe via a corresponding link. 

Please note that our newsletter contains advertising content, as we use it to offer our products and services. Your consent to the use of your email address is completely voluntary and your wish not to give your consent will have no further effect on the rest of the business relationship. 

The use of your email address in connection with the sending of our newsletter is based on your consent (Article 6 (1) (a) of the General Data Protection Regulation).

4.4 Registration for private areas

It is possible to register for private areas on our website. This registration is voluntary with the purpose of direct communication and fulfilment of orders between sales partners and us. 

Your personal data is processed for the fulfilment of a contract in which you are a contractual partner or for further contract initiation in accordance with the terms of use of the sales partner portal (Article 6 (1) (b) of the General Data Protection Regulation).

4.5 Registration for the Flossbach von Storch Postbox online platform

It is also possible to register for the Flossbach von Storch Postbox online platform. This registration is voluntary with the purpose of the protected exchange of confidential documents, particularly regular asset reports. During use, data is recorded that is used to trace error conditions in order to ensure comprehensive customer service in terms of troubleshooting during the login process. 

Only the following data is stored for this purpose:  

Session data, 
System events, 
Login data. 

Your personal data is processed to safeguard legitimate interests or to fulfil a contract in which you are a contractual partner or to initiate further contracts in accordance with the terms of use of Postbox (Article 6 (1) (b) and (f) of the General Data Protection Regulation).

4.6 Registration for telephone and web conferences and livestreams

We also offer the option of registering for telephone and web conferences and livestreams. Participation is voluntary with the purpose of direct communication and taking part in conferences. 

Your personal data is processed to protect our legitimate interests to organise conferences or to fulfil a contract to which you are a party or to initiate further contracts in accordance with the terms of use for telephone and web conferences (Article 6 (1) (b) and (f) of the General Data Protection Regulation).

4.6.1 GoToMeeting / LogMeIn

We use the GoToMeeting/LogMeIn software for online meetings, video and web conferences. This may result in data being transferred to the USA - the current EU standard contractual clauses have therefore been concluded with the provider to ensure an appropriate level of data protection. 

The "LogMeIn International Privacy Policy" can be found at: 

https://www.goto.com/company/trust/privacy

4.7 Cookies and analysis tools

In our Cookie Policy, you will find information about the processing of personal data using cookies and similar technologies on our website. 

5. More information about data processing

Information on your rights and more information on data processing can be found in our privacy statement at https://www.flossbachvonstorch.de/data-protection/

6. Subject to change

Flossbach von Storch Invest SE. reserves the right to amend this cookie guideline at any time in accordance with legal guidelines. For example, this may take place in order to comply with new statutory provisions or to take new cookie services on our website into account. We therefore recommend that you regularly visit our website to check our up-to-date data protection practices.

As of 15/10/2024