1.1
The data protection declaration contains information about the data processing when using our website at
https://viride.net and
https://invest.viride.net/ and the associated sub-pages (referred to collectively in this declaration as the "website").
1.2
By its nature, this privacy policy can only apply to the content on our web site and the server we use and does not include such content and third-party websites to which our offer merely links. This applies, for example, to links to social networks such as Facebook, LinkedIn, Instagram and YouTube. The processing of your personal data via these social networks is carried out by the respective operator of the network, without us having any influence on this processing. Information on the handling and protection of your personal data on these platforms can be found in the privacy policy of the respective platform.
2.
Responsibility and data protection officer
2.1
The responsible party for data processing on our website is:
Viride GmbH, Ahornweg 18, 61449 Steinbach (Taunus)
Phone: +49 6171 9519660
E-mail address: stefan@viride.net
2.2
You can reach our company data protection officer at:
Viride GmbH
Stefan Schmid
Ahornweg 18
61449 Steinbach (Ts.)
3.
Data collected when calling up the website
3.1
When you visit our website, the web server we use automatically logs information that your browser transmits to us. This is the IP address of the computer or other device you are using, the date and time (including time zone) of the respective access to the website as well as the information about which specific page or file was requested or delivered (i.e. in particular whether the file was delivered correctly), the amount of data transferred, the domain via which the respective request was made (so-called referrer URL), the operating system used and the browser used. The IP addresses are anonymized during storage.
3.2
We collect this data primarily to ensure the proper operation of our website, i.e. in particular for the purposes of system security and system administration, and also to optimize our internet offering, i.e. primarily for statistical purposes. The basis for this collection and processing is Art. 6 para. 1 p. 1 lit. f) DSGVO, whereby our legitimate interests are the security of our website and the improvement of our internet offer.
3.3
We do not pass this data on to third parties or link it to other data. Furthermore, this data is automatically deleted at regular intervals.
4.
User account registration and login area
4.1
We provide our users with a login area where users can manage their personal data, view further information on our projects and access documents (e.g. subscription form, consumer information, subordinated loan agreement, general terms and conditions & privacy policy).
4.2
To access our login area, registration of a user account or registration on the website is required. As part of the registration process, we collect the title, first name, last name, e-mail address and password of our users. Further data (e.g. title) can be provided optionally. In addition, the time of registration and the IP address are stored by us. In order to make sure that you are the owner of the given e-mail address and that you really want to register in our login area, we use the so-called double opt-in procedure. After successful registration, you will receive an e-mail with a link to confirm that you are the owner of the e-mail address and wish to register on our website.
4.3
The data stored in the user account includes the information provided during registration and, where applicable, further information provided voluntarily when using the website (e.g. information from the subscription form, see para. 5). The data is stored on servers in Germany. We generally store the data until the user account is deleted. If the user has also entered into a contractual relationship with us (e.g. has made an investment), the data will also be stored to the extent necessary for the duration of the contractual relationship and thereafter for up to three years or the expiry of the respective statutory retention period. For example, we are required by commercial and tax law to store address, payment and order data for a period of ten years. The legal basis for data processing in connection with the user account on our website is Art. 6 para. 1 p. 1 lit. b) DSGVO.
4.4
To prevent unauthorized access to your personal data by third parties, the connection is encrypted.
5.1
When using the forms integrated on our website (e.g. the form for the drawing section or contact form), we collect and process personal data to the extent provided by you.
5.2
The data collected as part of the subscription form includes, among other things, the investment amount, name, date of birth, address, place of residence, nationality, documents for proof of identity, e-mail address and bank information. Other information (e.g. tax number, information about your experience and knowledge of financial instruments) may be provided voluntarily. This data is processed for the purpose of processing the subscription request (including identity verification and risk assessment) and for the purpose of executing any contract that may have been concluded (e.g. for the payment of the return). The data will not be transmitted to third parties without the express consent of the user. The legal basis for the above processing is Art. 6 para. 1 p. 1 lit. b) DSGVO.
5.3
Certain information (but not name, date of birth, address, nationality, identity proof data, bank information or tax data) may be processed internally for statistical purposes, in particular target group analysis, which helps us to optimize our offer. The data evaluated for this purpose is aggregated into statistical reports and cannot be assigned to individual users and/or user profiles. The statistical results are not processed or stored in connection with user profiles. No data will be transmitted to third parties. The legal basis for this processing is Art. 6 para. 1 p. 1 lit. f) DSGVO, whereby our legitimate interest lies in the improvement of our offer.
5.4
Further personal data is collected if you enter it voluntarily on our website, in particular when making inquiries via our contact form or using our yield calculator. Of course, we also store and use this personal data only within the scope of what is legally permissible and to fulfill the purpose associated with the transmission, e.g. answering such an inquiry. The basis for this storage and use of these personal data is Art. 6 para. 1 p. 1 lit. b) DSGVO, insofar as you enter these personal data for the purpose of initiating a contract. Otherwise, this storage and use is based on Art. 6 para. 1 p. 1 lit. f) DSGVO, whereby our legitimate interest is the processing of your request.
5.5
To prevent unauthorized access to your personal data by third parties, the connection is encrypted.
6.1
Our website uses cookies and similar technologies (collectively "cookies") in several places. These are small text files or data records that are sent from the web server to your browser and stored by it, i.e. stored on your terminal device for later retrieval. Cookies cannot execute programs or transfer viruses to your computer. Cookies serve us to make our offer more user-friendly, more effective and safer, for example, by storing preferences you have selected during your visit in the presentation of our website for you and by providing us with information on the use of the offers of our website as well as other statistical information.
6.2
With regard to the storage period, the cookies used on the website can be distinguished as follows:
- Session Cookies: These cookies are automatically deleted when the browser is closed. They contain a so-called session ID. In this way, various requests from your browser can be assigned to the joint session and your computer can be recognized when you return to our website.
- Persistente Cookies: These cookies remain stored on your terminal device and are automatically deleted after a certain period of time (depending on the specific cookie from a few hours to two years) or at your instigation.
6.3
With regard to the purpose of use, the cookies used on the website can be roughly distinguished as follows:
- Necessary cookies: These cookies are technically necessary to navigate the website, use basic functions and ensure the security of the website; they do not collect information for marketing purposes nor do they store which other websites you visit. The storage of cookies on your terminal device and the access to these cookies are based on § 25 para. 2 no. 2 TTDSG.
- Optional cookies (preferences, statistics, marketing): These cookies can, among other things, record your interactions on the website and are used for analysis or marketing purposes. The use of these cookies (i.e. their storage on your terminal device and access to these cookies) takes place exclusively with your express, active consent, which can be freely revoked at any time, pursuant to Section 25 (1) TTDSG. This is obtained in our cookie banner and can also be revoked here. You can find more information about the functions of these cookies in our cookie banner and in the following explanations of this data protection declaration (in each case for the website function or the service that uses the cookies).
6.4
You can usually delete cookies stored by your browser yourself via the settings of your browser and set your browser so that it informs you accordingly and asks for permission before storing a cookie.
7.1
With your consent, our website uses Google Analytics. This is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland ("Google"), which uses cookies to analyze your user interactions on our website. Through the statistics and reports obtained, we would like to improve our offer and make it more interesting for you.
7.2
Google Analytics uses cookies that enable an analysis of your use of the website. The information generated by cookies about your use of the website is usually transferred by Google to a Google server in the USA and stored there. Google Analytics also collects the IP address of your terminal device to ensure the security of the service and to provide us, as the website operator, with information about the country, region or location from which the website is used (so-called "IP location determination"). We use Google Analytics exclusively with the extension "_anonymizehelp()". By activating this extension for our website, your IP address is shortened before being transmitted to a Google server in the USA within the member states of the EU or other contracting states of the Agreement on the European Economic Area. Google uses the information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage to us.
7.3
Google also processes the data collected via Google Analytics for its own purposes to the extent in accordance with its own privacy policy. The data may be stored by Google in usage profiles and processed, for example, to improve products, develop new products, measure the effectiveness of certain advertising and market research, and personalize content and advertisements. If you are logged in to Google, your data will be directly assigned to your user account. If you do not want the assignment to your user account at Google, you must log out before activating Google Analytics. We have no influence on the further processing of your data by Google. You can find more information on this in
Google's privacy policy.
7.4
Further details on data processing within the scope of Google Analytics are available
here and
here.
7.5
We would like to point out that there may be additional risks associated with the transfer of data to the USA, for example, it may be more difficult to enforce your rights to this data or certain US authorities may gain access to this data. Please be aware that you consent to this transfer of data to the USA when you give us your consent to use Google Analytics. The transfer of data to the USA is therefore based on your consent pursuant to Art. 49 (1) a) DSGVO. In addition, we have also agreed with Google on standard data protection clauses of the EU Commission according to Art. 46 para. 2 lit. c) DSGVO. These standard data protection clauses are intended to ensure that an appropriate level of data protection is maintained in the third country (USA).
7.6
We activate Google Analytics (including the MonsterInsights plugin as stated in para. 8 indicated) only if you consent to the processing of your data by the Google Analytics service. The legal basis for data processing in connection with the integration of Google Analytics on our website is therefore Art. 6 para. 1 p. 1 lit. a) DSGVO. You can revoke an already granted consent at any time with effect for the future, for example by deselecting the category "Statistics" in the settings of our cookie banner. Alternatively, you can also install the browser plugin from Google to disable Google Analytics, which can be downloaded
here.
8.1
With your consent, our website uses the "Google Analytics Plugin for WordPress". This is a plugin from MonsterInsights LLC, 7732 Maywood Crest Dr, West Palm Beach, Florida 33412, USA ("MonsterInsights"), which is linked to the Google Analytics web analytics service (see above). The plugin helps us to integrate Google Analytics on our website and to manage the data collected with Google Analytics. The plugin thus helps to obtain statistical reports on the use of the website and thus serves (just like Google Analytics) to improve our offer.
8.2
MonsterInsights does not use its own cookies and instead embeds Google Analytics on the website. Therefore, MonsterInsights does not store its own data, but forwards it to Google, where the storage and processing of the data takes place. You can find more information about Google's data processing under para. 7 in this privacy policy. The statistical reports generated by Google Analytics are in turn transmitted to MonsterInsights, where we can access them via a dashboard. MonsterInsights thus
8.3
We only activate MonsterInsights if you consent to the processing of your data by Google Analytics (including MonsterInsights). The legal basis for data processing in connection with the use of MonsterInsights is therefore Art. 6 para. 1 p. 1 lit. a) DSGVO. You can revoke an already granted consent at any time with effect for the future, for example by deselecting the category "Statistics" in the settings of our
Cookie-Banner.
9.
Use of Meta, Google and LinkedIn marketing tools
9.1
Purpose of data processing
We want to play our users advertising content that is as interest-based and relevant to them as possible. To do this, we need to understand which products offered on our website interest the individual user and how successful our previous advertising measures have been. To determine this, we use so-called "marketing" tools that allow,
- to record visitor behavior on the website (e.g. clicks on certain links and products; retrieval of certain sub-websites) and, if necessary, to evaluate it in advertising profiles (so-called "tracking"),
- to play targeted personalized advertising (e.g. previously viewed products) to users on other websites (so-called "retargeting"),
- track the user's interactions with our advertising measures (e.g. click on the ad) and thereby measure the success of the advertising measures (so-called "conversion tracking").
The marketing tools are thus used to play out personalized advertising and measure the effectiveness of our advertising measures. The advertising is played out in the advertising networks of LinkedIn and Facebook.
9.2
Meta Pixel
The website uses the so-called Meta Pixel (formerly Facebook Pixel) from Meta Inc. (formerly Facebook), Hacker Way, Menlo Park, CA 94025, USA. By integrating the Meta Pixel on our website, we can display our advertising measures ("Facebook Ads") to users of our website and the social network Facebook and measure and evaluate the success. For this purpose, among other things, marketing cookies are set on our website, which are stored for a maximum of 180 days and then automatically deleted.
9.3
Google Ads (including conversion tracking)
The website uses the Google Ads offer, including the conversion tracking function, to display advertisements in the search engines and on the pages of Google and Google's partners ("Google advertising network"). Google Ads is offered by Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland ("Google"). For the offer, among other things, marketing cookies are set on our website, which are stored on your terminal device for a maximum of two years.
You can disable Google's use of cookies by visiting the Google Advertising Disablement page.
9.4
LinkedIn Pixel
The website uses the so-called LinkedIn pixel (or LinkedIn Insight tag) of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). The integration of this JavaScript tag enables us to display and measure personalized advertising as described above when users visit the LinkedIn social network or other websites that have also integrated the LinkedIn advertising network. For this purpose, among other things, marketing cookies are set on our website, which are stored for a maximum of 6 months and then automatically deleted.
The deactivation of the LinkedIn Insight tag and other advertising objections are possible in the settings for advertisements and supplementary here.
9.5
Data processing by the providers of the marketing tools
By integrating the above marketing tools, your browser automatically establishes a direct connection with the server of the respective provider. The respective provider is solely responsible for the processing of the transmitted data to carry out the described purposes. The providers therefore decide independently on the specific advertising played out. In this respect, we can only make rough restrictions in advance when ordering the advertising on the basis of some presettings limited by the provider of the marketing tool, which user categories can potentially be shown our advertising.
We have no influence on the scope and further use of the data collected using these marketing tools. We therefore inform you according to our state of knowledge: By integrating the respective tool on our website, the respective provider receives information about your activities on our website or in connection with our advertising (e.g. the information that you have accessed the corresponding website of our internet presence or clicked on an ad of ours), your IP address, date and time of the activity and information about your end device. The data may be stored by the respective provider in user profiles, on the basis of which the providers or third-party providers play out personalized advertising, for example on third-party sites. In addition, the providers may also process the data, for example, to improve products, develop new products, measure the effectiveness of certain advertising and market research. If you are registered with one of the services (Facebook, Google, LinkedIn), the respective provider may be able to assign the transmitted information to your account. Even if you are not registered with the service or have not logged in, there is a possibility that the respective provider may learn your IP address, time slots and other identifying characteristics and link them to the actions assigned to you.
For more information on data processing at the providers, please see the links below.
9.6
Data transfer to third countries (especially the USA)
The information collected is stored on servers of the respective provider in countries outside the European Economic Area, including the USA. As already explained, there are additional risks associated with the transfer of data to the USA. Please be aware that you agree to this data transfer to the USA when you give us your consent to use marketing tools. The data transfer to the USA is therefore based on your consent pursuant to Art. 49 (1) a) DSGVO. In addition, the standard data protection clauses of the EU Commission pursuant to Art. 46 (2) (c) DSGVO have also been agreed in each case for the respective data transfers. These standard data protection clauses are intended to ensure that an appropriate level of data protection is maintained in the third country (USA).
9.7
Legal basis
The legal basis for data processing by the above marketing tools is in each case your consent pursuant to Art. 6 (1) p. 1 lit. a) DSGVO. Any consent given can be freely revoked at any time with effect for the future. Consents are obtained in our cookie banner and can also be freely revoked.
10.1
We use the "Google Tag Manager" on our website, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). The Google Tag Manager allows us to manage website tags via an interface. Google Tag Manager, which implements the tags, is a cookie-less domain and does not collect any personal data itself. Google Tag Manager provides for the triggering of other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it remains in place for all tracking tags implemented with Google Tag Manager.
10.2
Further information on data protection can be found on the following Google web pages:
11.
Our appearances in social networks
11.1
We have presences (so-called "fan pages") on the following social networks and providers:
11.2
For the operation of the respective fan page, we rely on the technical platform and services of the providers. We would like to point out that you use our fan pages on social networks and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). When you visit our fan pages, the providers of the social networks collect certain technical data (including the IP address of your terminal device) as well as other information that is present on your terminal device in the form of cookies. This information is used to provide us, as operators of the fan pages, with statistical information about the interaction with our fan pages.
11.3
We have no influence on and no precise knowledge of how the providers process the data from the visit to our fan page and from the interactions with our posts for their own purposes, how long these are stored and whether the data are passed on to third parties. Data processing may differ depending on whether you are registered and logged in to the social network or visit the page as a non-registered and/or non-logged-in user. When you access the fan page or a post, the IP address assigned to your terminal device is transmitted to the provider of the respective social network. If you are currently logged into the social network, a cookie on your end device can be used to track how you have moved around the network. Buttons embedded in websites enable the platforms to record your visits to these websites and assign them to your respective profile. Based on this data, content or advertising can be offered tailored to you. If you wish to avoid this, you should log out or deactivate the "stay logged in" function, delete the cookies present on your device and restart your browser. Please also note that the data collected about you in this context may be transferred by the respective provider of the social network to countries outside the European Economic Area (EEA), in particular the USA, and processed there.
11.4
For further information on data processing by the providers of the social networks, including any data transfer to third countries, please refer to the data protection notices of the respective provider linked above. There you will also find information on contact options and on the settings options for advertisements.
11.5
We operate our fan page in the respective social network in order to communicate with the users active there and to be able to provide current messages. We process the data from your use of the fan page that you provide to us and that requires interaction. For example, if you ask us a question via a fan page, we process your information to answer the request appropriately. When you visit our fan pages on Instagram LinkedIn, the respective providers of the social network also process personal data to provide us with statistics and insights (so-called "insights") into the use of our fan pages. The statistics serve us to adapt our fan pages according to user needs and thus to continuously optimize them, which can also be done for market research and advertising purposes. In this context, we only receive statistical reports through which we cannot identify or draw conclusions about the individual users of the social network. The processing of data for statistical purposes is carried out by us and the providers of the social network under joint responsibility in accordance with Art. 26 DSGVO. We have regulated the conditions and obligations as joint controllers with the providers in each case in an agreement, which is available
here.
11.6
The data processing by us serves to protect our legitimate interests in the operation of a fan page on the respective social network, the communication and interaction with the users of this social network, and the evaluation of user interactions to improve the fan page. The data processing is thus based in each case on Art. 6 para. 1 p. 1 lit. f) DSGVO.
11.7
To exercise your data subject rights, you can contact both us or the provider of the respective social network. To the extent that one party is not responsible for responding or must receive the information from the other party, we or the provider will then forward your request to the respective partner. Please contact the respective social network provider directly for questions about the profiling and processing of your data when using the fan page. For questions about the processing of your interaction with us on our fan page, please write to the contact details we have provided above.
12.
Disclosure of personal data
12.1
Your personal data will only be passed on to other third parties with your express consent. The only exceptions to this are transfers to our service providers listed above or technical service providers that we need to provide the offer or this website and have commissioned accordingly (for example, technical service providers or hosting services). The service providers process this data exclusively in accordance with instructions on our behalf and we have concluded corresponding contracts on commissioned processing pursuant to Art. 28 DSGVO with these service providers. Of course, before transferring your personal data, we ensure that the service providers have taken the necessary technical and organizational measures to ensure an appropriate level of protection. The scope of the data transfer is limited to the minimum necessary in each case.
12.2
In individual cases, data may also be transferred to the following recipients:
- To our partners or third parties, insofar as the transmission of the data is necessary for the initiation or execution of a contract to be concluded or concluded with you pursuant to Art. 6 para. 1 p. 1 lit. b) DSGVO.
- To state institutions and authorities entitled to receive information, insofar as we are obligated to provide information within the scope of the legal obligations to provide information or by a judicial or official decision. In this case, the disclosure of your data is required by Art. 6 para. 1 p. 1 lit. c) DSGVO to fulfill a legal obligation to which we are subject.
- To lawyers and/or external consultants, insofar as this is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that the data subject has an overriding interest worthy of protection in the non-disclosure of his or her data. In this case, the data is disclosed on the basis of Art. 6 (1) p. 1 lit. f) DSGVO to protect our legitimate interest, which is the assertion, exercise or defense of legal claims.
13.
Protection of your data and storage period
13.1
We have put in place appropriate technical and organizational measures to protect your personal data from unauthorized access, use or disclosure and ensure that any personal data is in a controlled, secure environment, protected from unauthorized access to the best of our ability.
13.2
We will only process your personal data for as long as is necessary to achieve the purpose of the processing. As soon as the purpose of processing ceases to apply, we will delete your data without delay, unless there are legitimate reasons within the meaning of the applicable legal regulations (for example, Art. 17 (3) DSGVO), such as, in particular, legally required retention periods, to the contrary. In this case, the data will be deleted immediately after the expiry of the retention period.
13.3
Data that we process on the basis of your consent will generally be deleted immediately after you revoke your consent, unless legal regulations prevent such deletion.
14.1
As a person affected by data processing, you are entitled to the following rights - in each case under the legal conditions and to the legal extent. You have the right to
- to receive information about the processing of your personal data (Art. 15 DSGVO),
- without undue delay, rectify any inaccurate personal data concerning you and/or complete any incomplete personal data (Art. 16 GDPR);
- demand the immediate deletion of the personal data concerning you (Art. 17 DSGVO);
- request the restriction of data processing concerning you (Art. 18 DSGVO);
- to receive the personal data concerning you that you have provided in a structured and machine-readable format and to transfer this data to another controller (Art. 20 DSGVO);
- object, on grounds relating to your particular situation, to the processing of personal data concerning you, where the processing is based on a legitimate interest; where your data is used for the purposes of direct marketing, you have the right to object at any time (Article 21 GDPR);
- revoke your consent to data processing at any time without affecting the lawfulness of the data processing carried out on the basis of the consent until the revocation (Art. 7 (3) DSGVO);
- complain to a supervisory authority about the processing of your data (Art. 77 DSGVO).
15.1
We do not use automated decision-making in accordance with Article 22 (1) and (4) of the GDPR, i.e. we do not use web-based systems to create user profiles and make automated decisions based on them that have a legal effect or similar impact on you.
15.2
You are not contractually or legally obligated to provide personal data on the website. However, without the provision of the protocol data (see under section 2.1), the website can usually not be used.
15.3
If you have any further questions that have not been answered by this data protection declaration, or if you would like more detailed information on individual points, please feel free to contact us at any time using the contact details mentioned at the beginning.
We reserve the right to change the measures and specifications described here - within the framework of existing legal regulations - insofar as this is indicated, for example, due to new technical developments or changes in case law or our business operations. Therefore, we ask you to always observe the current version of this privacy policy.
[Steinbach (Taunus), January 2023]
