DEFINITIONS AND INTERPRETATION
In this Policy, the following terms shall have the following meanings: “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you provide to us via the Website or which we collect when you use our Website, e.g. your name, address, e-mail address, IP address, etc. This definition shall, where applicable, incorporate the definition provided in the General Data Protection Regulation (“GDPR”); and “we/us/our” means 777 Financial Advisors GmbH, a company in Germany whose address is Bockenheimer Landstraße 2-4, 60306 Frankfurt am Main.
SCOPE OF THIS POLICY
This Policy applies only to your use of the Website with regard to 777. The Website may contain links to other websites. Please note that we have no control over how your personal data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Please note that where this Policy explains applicable law and your rights, this applies only to personal data which is processed under the GDPR.
Subject to certain legal conditions, as a data subject you have the following rights under the GDPR: you may request access to, rectification, erasure or restriction of processing of your personal data. You may also object to processing or request data portability. In particular you have the right to request a copy of the personal data that we hold about you. If you make this request repeatedly, we may make an adequate charge for this. Please refer to Articles 15-22 of the GDPR for details on your data protection rights.
If you have given us your consent for the processing of your personal data, you may withdraw your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If you withdraw your consent, we will only continue processing your personal information where there is another legal ground or where we are legally required to do so.
For any of the above requests, please send a description of your personal data concerned and appropriate proof of identity to the contact details below. We may require additional proof of identity to protect your personal data against unauthorized access. We will carefully consider your request and may discuss with you how it can best be fulfilled.
If you have any concerns about how your personal data is handled by us or wish to raise a complaint on how we have handled your personal data, you can contact us at the contact details below to have the matter investigated. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the competent data protection supervisory authority in your country.
WHAT DATA DO WE COLLECT?
If you send us an email or contact us via our website we may collect your name, your email address, your domicile, your profession and any other personal data which you choose to give us or which is required by the contact form.
When using this Website we collect such data that your browser sends to our server (so-called “server log files”). When you access this Website, we collect data, which is technically necessary for us to show you the Website including date and time at the time of your access, amount of data sent in bytes, source/reference from where you came to the page, browser used, operating system used, IP address used.
It is possible that we process information from publicly available resources, e.g. integrity data bases, and information we are legally required to collect to comply with our legal or regulatory obligations, which may include information about relevant and significant litigation or other legal proceedings against you or a third party related to you.
HOW DO WE USE YOUR DATA?
If we do collect any personal data, it will be processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. We will always comply with our obligations and safeguard your rights under the GDPR. For more details on security see section 7 below.
FOR WHICH PURPOSES DO WE USE YOUR PERSONAL DATA?
We may process your personal data for the following purposes:
- to enhance the quality of our services as well as to maintain contact details for those with whom we interact;
- to maintain and protect the security of our IT systems, Website or other digital infrastructure, preventing and detecting security threats, fraud or other criminal or malicious activities;
- to establish, exercise or defend legal claims;
- to communicate with you through the channels you have approved to keep you up to date;
- if you contact us and we obtain your personal details from your email or our contact form, we may use them as follows:
- to reply to your email or the contact from;
- to reply to any other request submitted by you and the technical administration associated with this.
- Profiling and automated processing: Collecting information about your preferences on the basis of your activities when you use this Website. On the basis of this information (e.g. which content clicked or viewed for how often and how long), we may create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics). The logic behind our profiling activities is to identify areas which may be useful or otherwise of interest for you and to inform you about such areas in a more effective and targeted way.
Please note: Under the GDPR you have the right to object to the use of your personal data for direct marketing purposes, including profiling. Please refer to “Your rights” above for further explanation of your rights and how to exercise them. In the event a consent was given, you have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
ON WHICH BASIS DO WE PROCESS YOUR INFORMATION?
We will process your personal data for the above purposes only
- where it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into such a contract;
- where it is necessary for our or a third party’s legitimate interests, always provided that such interests are not overridden by your interests or fundamental rights and freedoms. Our “legitimate interests” may include our commercial interests in operating our business and our Website in a professional, sustainable manner, in accordance with all relevant legal and regulatory requirements;
- for our compliance with our legal obligations;
- where it is necessary to protect your or another person’s vital interests;
- where we have obtained your specific or, where necessary, explicit consent to do so.
The legal bases for processing of your personal data are set forth in Article 6 of the GDPR.
HOW AND WHERE DO WE PROCESS YOUR PERSONAL DATA?
We will retain your personal data in accordance with applicable data protection laws for so long as it is required to provide you with the services or information you have requested and to execute and administer your relationship with us. If you have asked us not to communicate with you, we will hold this information as long as required to comply with your request. We may also be required to keep certain of your personal data for certain retention periods under applicable law. Your personal data will be promptly deleted when it is no longer required for these purposes.
Your data will be stored in Switzerland and in the European Union. In the course of our business activities, we may transfer your personal data also to recipients in countries outside of the European Union or Switzerland (“third countries”), in which applicable laws do not offer the same level of data protection. When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data, in particular by entering into the EU Standard Contractual Clauses which are available here. You may contact us anytime using the contact details below if you would like further information on such safeguards.
Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure any data we hold about you (even if it is only your email address). We maintain physical, electronic and procedural safeguards in accordance with the technical state of the art and legal data protection requirements to protect your personal data from unauthorized access or intrusion. These safeguards include implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and encryption. We will at all times strictly comply with applicable laws and regulations regarding the confidentiality and security of personal data.
WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
We may share your personal data to the extent permitted by law as follows:
- With our affiliates worldwide if and to the extent required for the purposes above and as legally permitted. In such cases, these entities will then use the personal data for the same purposes and under the same conditions as outlined in this Policy.
- We may also instruct service providers (so called data processors) within or outside of our group, domestically or abroad to process personal data for the purposes above on our behalf and in accordance with our instructions only. We will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.
- With courts, regulators, law enforcement or other competent authorities or legal advisors if legally permitted and necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
- We may also share your personal data with third parties if we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets, along with its professional advisers. If we or substantially all of its assets are acquired by a third party, personal data held by us will be one of the transferred assets.
Otherwise, we will only disclose your personal data when you direct or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or when we suspect fraudulent or criminal activities.
ARE YOU REQUIRED TO PROVIDE PERSONAL DATA?
As a general principle, you will provide us with your personal data entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which we cannot take action without certain of your personal data, for example because this personal data is required to process your requests, provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data.
Newsletters are sent only to users who specifically ask to receive them. By subscribing to a newsletter, you agrees that your email address may be used by us to send out newsletters. With each newsletter, we offer the option of correcting, updating or removing the information that you have provided. Users can unsubscribe from our newsletters at any time, using a link provided in every email. We do track openings and clicks on our newsletters in order to improve our offering and to increase the relevance to your interests.
If you have any questions about the Website or this Policy and your rights, please contact us by email at email@example.com. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
CHANGES TO OUR POLICY
We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on the Website. We recommend that you check this page regularly to keep up-to-date.