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Privacy Policy

We are pleased that you are visiting our website. The protection and security of your personal information when using our website is very important to us. We would therefore like to inform you here about which of your personal data we collect when you visit our website and for what purposes it is used.

This privacy policy applies to the online offering of 1970 Asset Management GmbH, which is accessible at the domain https://1970am.com and its various subdomains ("our website").

Who is responsible and how can you reach us?

Controller

responsible for the processing of personal data within the meaning of the EU General Data Protection Regulation (GDPR)

1970 Asset Management GmbH
Michael Diegelmann
Kapellenstr. 64 B
65193 Wiesbaden, Germany
Email: diegelmann@1970am.com

Data Protection Officer

Our data protection officer is

StraSev UG (haftungsbeschränkt)
Jana-Alice Stratmann-Severin
Diekweg 16, 26160 Bad Zwischenahn, Germany
Phone: 0800 151 1751
Email: datenschutz@strasev.de

What is this about?

This privacy policy fulfils the legal requirements for transparency in the processing of personal data. Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, email address, IP address, or your user behaviour when visiting a website. Information for which we cannot (or only with disproportionate effort) establish a reference to your person, e.g. through anonymisation, is not personal data.

The processing of personal data (e.g. collecting, querying, using, storing, or transmitting) always requires a legal basis and a defined purpose.

Stored personal data is deleted as soon as the purpose of processing has been achieved and there are no lawful grounds for further retention of the data. We will inform you about the specific storage periods or criteria for storage in the individual processing operations. Irrespective of this, in individual cases we store your personal data for the establishment, exercise, or defence of legal claims and where statutory retention obligations exist.

Who receives my data?

We only pass on the personal data we process on our website to third parties if this is necessary to fulfil the purposes and is covered in the individual case by the legal basis (e.g. consent or the safeguarding of legitimate interests). In addition, in individual cases we pass on personal data to third parties if this serves the establishment, exercise, or defence of legal claims. Possible recipients may then be, for example, law enforcement authorities, lawyers, auditors, courts, etc.

Insofar as we use service providers to operate our website who process personal data on our behalf pursuant to Art. 28 GDPR, these may be recipients of your personal data. Further information on the use of processors and web services can be found in the overview of the individual processing operations.

Do you use cookies?

Cookies are small text files that are sent by us to the browser of your device during your visit to our websites and stored there. As an alternative to the use of cookies, information can also be stored in the local storage of your browser. Some functions of our website cannot be offered without the use of cookies or local storage (technically necessary cookies). Other cookies, on the other hand, enable us to carry out various analyses, so that, for example, we are able to recognise the browser you use on a renewed visit to our website and to transmit various information to us (non-essential cookies). Among other things, cookies enable us to make our website more user-friendly and effective for you, for instance by tracking your use of our website and identifying your preferred settings (e.g. country and language settings). Insofar as third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your device. They cannot run programs and cannot contain viruses.

We currently do not use any cookies!

What rights do I have?

Subject to the conditions of the statutory provisions of the General Data Protection Regulation (GDPR), you have the following rights as a data subject:

  • Access pursuant to Art. 15 GDPR to the data stored about you in the form of meaningful information on the details of the processing, as well as a copy of your data;
  • Rectification pursuant to Art. 16 GDPR of incorrect or incomplete data stored by us;
  • Erasure pursuant to Art. 17 GDPR of the data stored by us, insofar as the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defence of legal claims;
  • Restriction of processing pursuant to Art. 18 GDPR, insofar as the accuracy of the data is contested, the processing is unlawful, we no longer need the data and you refuse its erasure because you require it for the establishment, exercise, or defence of legal claims, or you have objected to the processing pursuant to Art. 21 GDPR;
  • Data portability pursuant to Art. 20 GDPR, insofar as you have provided us with personal data on the basis of consent pursuant to Art. 6 (1) lit. a GDPR or on the basis of a contract pursuant to Art. 6 (1) lit. b GDPR and this has been processed by us using automated procedures. You will receive your data in a structured, commonly used, and machine-readable format, or we will transmit the data directly to another controller, insofar as this is technically feasible;
  • Objection pursuant to Art. 21 GDPR to the processing of your personal data, insofar as this is carried out on the basis of Art. 6 (1) lit. e, f GDPR and there are grounds arising from your particular situation, or the objection is directed against direct marketing. The right to object does not exist if compelling legitimate grounds for the processing are demonstrated that override your interests, or if the processing serves the establishment, exercise, or defence of legal claims. Where the right to object does not exist for individual processing operations, this is indicated there;
  • Withdrawal pursuant to Art. 7 (3) GDPR of the consent you have given, with effect for the future;
  • Complaint pursuant to Art. 77 GDPR to a supervisory authority if you believe that the processing of your personal data violates the GDPR. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work, or our company headquarters.

How is my data processed in detail?

Below we inform you about the individual processing operations, the scope and purpose of the data processing, the legal basis, the obligation to provide your data, and the respective storage period. Automated decision-making in individual cases, including profiling, does not take place.

Provision of the website

Type and scope of processing

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a so-called log file:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Website from which access is made (referrer URL)
  • Browser used and, where applicable, the operating system of your computer, as well as the name of your access provider

Our website is not hosted by us, but by a service provider that processes the aforementioned data on our behalf pursuant to Art. 28 GDPR for the purpose of providing the website.

Purpose and legal basis

The processing is carried out to safeguard our overriding legitimate interest in displaying our website and ensuring its security and stability, on the basis of Art. 6 (1) lit. f GDPR. The collection of the data and its storage in log files is strictly necessary for the operation of the website. There is no right to object to the processing due to the exception under Art. 21 (1) GDPR. Insofar as the further storage of the log files is required by law, the processing is carried out on the basis of Art. 6 (1) lit. c GDPR. There is no statutory or contractual obligation to provide the data; however, accessing our website is technically impossible without providing the data.

Storage period

The aforementioned data is stored for the duration the website is displayed and, for technical reasons, beyond this for a maximum of 7 days.

Contact form

Type and scope of processing

On our website we offer you the option of contacting us via a form provided. The information collected via mandatory fields is required in order to process the enquiry. In addition, you may voluntarily provide additional information that, from your point of view, is necessary for processing the contact enquiry.

When using the contact form, your personal data is not passed on to third parties.

Purpose and legal basis

The processing of your data through the use of our contact form is carried out for the purpose of communication and handling your enquiry on the basis of your consent pursuant to Art. 6 (1) lit. a GDPR. Insofar as your enquiry relates to an existing contractual relationship with us, the processing is carried out for the purpose of contract performance on the basis of Art. 6 (1) lit. b GDPR. There is no statutory or contractual obligation to provide your data; however, your enquiry cannot be processed without providing the information in the mandatory fields. If you do not wish to provide this data, please contact us by other means.

Storage period

Insofar as you use the contact form on the basis of your consent, we store the data collected for each enquiry for a period of three years, beginning with the completion of your enquiry or until you withdraw your consent.

Should you use the contact form within the scope of a contractual relationship, we store the data collected for each enquiry for a period of three years from the end of the contractual relationship.

Netlify (web hosting)

Type and scope of processing

We use Netlify as the web hosting provider for our website. The service provider is the US company Netlify, Inc., 2325 3rd Street, Suite 29, San Francisco, CA 94104, USA. When our website is accessed, Netlify processes technical connection data, in particular your IP address and, where applicable, browser data such as your user agent, which is automatically transmitted to Netlify's servers when our website is loaded. This data is processed exclusively for the purposes stated above and to maintain the security and functionality of the hosting service.

Purpose and legal basis

The use of Netlify is based on our legitimate interests, i.e. our interest in the secure and efficient provision as well as the optimisation of our online offering pursuant to Art. 6 (1) lit. f GDPR. The transfer of data to the USA is carried out on the basis of the European Commission's adequacy decision and Netlify, Inc.'s certification under the EU-US Data Privacy Framework. In addition, Netlify uses Standard Contractual Clauses pursuant to Art. 46 (2) and (3) GDPR in order to ensure an adequate level of data protection when processing personal data in the USA.

Storage period

The specific storage period of the processed data cannot be influenced by us, but is determined by Netlify, Inc. Further information can be found in Netlify's privacy policy: netlify.com/privacy.

AWS – Amazon Web Services (Provider)

Type and scope of processing

We use Amazon Web Services (AWS), among other things a web hosting provider, for our website. The service provider is the US company Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA.

Purpose and legal basis

Amazon also processes your data, among other places, in the USA. Amazon is an active participant in the EU-US Data Privacy Framework, which governs the correct and secure transfer of personal data of EU citizens to the USA. You can find more information on this at commission.europa.eu.

In addition, Amazon uses so-called Standard Contractual Clauses (= Art. 46 (2) and (3) GDPR). Standard Contractual Clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even when transferred to and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Amazon undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses, among other places, here: eur-lex.europa.eu.

The AWS Data Processing Addendum (DPA), which contains the Standard Contractual Clauses, can be found at d1.awsstatic.com.

Storage period

The specific storage period of the processed data cannot be influenced by us, but is determined by Amazon. Further information can be found in Amazon's privacy policy at aws.amazon.com/de/privacy.

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