BPM - Berlin Portfolio Management GmbH
Uhlandstraße 33 - 10719 Berlin
Tel.: +49 30 8871087-0
Fax: +49 30 8871087-29
Directeurs: Uwe Günther, Thomas Pass
Kamer van Koophandel: B128935 - AG Berlin Charlottenburg
volgens § 15 van het WpIG (Duitse Bankwet): registratienummer 123 635
en artikel 32 EU richtlijn MiFID (Markets in Financial Instruments Directive
Aanbieder op het internet i.v.m. § 5 Tele Mediawet (TMG): BPM - Berlin Portfolio Management GmbH
Data Protection Policy
Thank you for your interest in our company. Data protection is of particular importance to the management of BPM - Berlin Portfolio Management GmbH. A use of the Internet pages of BPM - Berlin Portfolio Management GmbH is possible without any indication of personal data. However, if a person concerned wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.
The processing of personal data, for example the name, address, e-mail address or telephone number of a person concerned, is always carried out in accordance with the basic data protection regulation and in accordance with the country-specific data protection regulations applicable to BPM - Berlin Portfolio Management GmbH. By means of this data protection policy, our company would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, person concerneds will be informed of their rights by means of this data protection policy.
BPM - Berlin Portfolio Management GmbH has implemented numerous technical and organizational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, for example by telephone.
1. Name and address of the responsible party
The party responsible within the meaning of the data protection regulation, other data protection laws in force in the member states of the European Union and other provisions of a data protection nature is:
BPM - Berlin Portfolio Management GmbH
10719 Berlin, Germany
An external company data protection officer pursuant to Article 37 of the EU General Data Protection Regulation (GDPR / DSGVO) has been appointed:
Dipl.-Inform. Thomas Ziemer
12316 Berlin, Germany
Appointment as data protection officer from 24.05.2018.
The data protection declaration of BPM - Berlin Portfolio Management GmbH is based on the terms used by the European guideline and regulation provider in the adoption of the EU General Data Protection Regulation (GDPR). These are explained in Article 4 GDPR.
3. Collection of general data and information
The website of BPM - Berlin Portfolio Management GmbH collects a series of general data and information every time a person or an automated system accesses the website. This general data and information is stored in the log files of the server. We may record (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the Website, (6) an Internet Protocol address (IP address), (7) the Internet service providers of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.
When using this general data and information, BPM - Berlin Portfolio Management GmbH does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimize the contents of our website and the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. These anonymously collected data and information are therefore evaluated statistically by BPM - Berlin Portfolio Management GmbH, also with the aim of increasing data protection and data security in our company in order to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.
By using cookies, BPM - Berlin Portfolio Management GmbH can provide users of this website with more user-friendly services that would not be possible without cookies.
By means of a cookie, the information and offers on our website can be optimized for the user. Cookies enable us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website.
The person concerned can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, not all functions of our Internet site may be fully usable.
5. Possibility to contact us via the website
Due to legal regulations, the website of BPM - Berlin Portfolio Management GmbH contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a person concerned contacts the data controller via e-mail or a contact form, the personal data transmitted by the person concerned will be stored automatically. Such personal data voluntarily provided by a person concerned to the controller will be stored for the purpose of processing or contacting the person concerned. This personal data is not passed on to third parties.
6. Routine deletion and blocking of personal data
The controller shall process and store the personal data of the person concerned only for the time necessary to achieve the purpose of the data retention or to the extent provided for by the European directives and regulations or any other legislature in laws or regulations to which the controller is subject. If the storage purpose ceases to apply or if a storage period prescribed by the European directives and regulations or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with the statutory provisions.
7. Rights of the person concerned
7.1 Right to confirmation
Each affected person has the right, as granted by the European legislator and regulator, to require the responsible party to confirm whether personal data relating to him / her is being processed. If an affected person wishes to make use of this confirmation right, they can contact our data protection officer or another employee of the responsible party at any time.
7.2 Right to information
Any person affected by the processing of personal data shall have the right granted by the European legislator and regulator to obtain at any time, free of charge, from the responsible party any personal data stored about him or her and a copy of that information. Furthermore, the European legislator and regulator has granted the affected person disclosure of the following:
- the processing purposes
- the categories of personal data being processed
- the recipients or categories of recipients to whom the personal data have been disclosed or are still being disclosed, in particular to recipients in third countries or to international organizations
- if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining that duration, the right to rectification or erasure of the personal data or restriction of the processing by the responsible party
- the existence of a right to complain to a supervisory authority if the personal data are not collected from the affected person: all available information on the origin of the data the existence of automated decision-making including profiling in accordance with Article 22 paragraphs 1 and 4 GDPR / DSGVO and - at least in these cases - provide meaningful information about the logic involved and the scope and intended impact of such processing on the affected person
In addition, the affected person has a right of access as to whether personal data has been transmitted to a third country or to an international organization. In this case, the affected person has the right to obtain information about the appropriate guarantees in connection with the transfer.
If an interested party wishes to exercise this right to information, they may at any time contact an employee of the responsible party. (Article 15 (1) GDPR / DSGVO)
7.3 Right to rectification
Any person affected by the processing of personal data has the right granted by the European legislator to demand the immediate correction of incorrect personal data concerning him / her. Taking the purpose of the processing into account, the affected person has the right to request the completion of incomplete personal data, also by means of a supplementary declaration.
If an affected person wishes to exercise this right of rectification, they may, at any time, contact an employee of the responsible party. (Article 16 GDPR / DSGVO)
7.4 Right to cancellation (right to be forgotten)
Any person affected by the processing of personal data shall have the right granted by the European legislators and regulators to require the responsible party to immediately delete the personal data concerning him / her, provided that one of the following reasons is satisfied and the processing is not required:
- The personal data has been collected for such purposes or otherwise processed for which they are no longer necessary.
- The affected person revokes their consent, on which the processing was based in accordance with Article 6 (1) (a) of the GDPR or Article 9 (2) (a) GDPR / DSGVO, and there is no other legal basis for the processing.
- The affected person submits an objection to the processing pursuant to Art. 21 (1) GDPR / DSGVO, and there are no legitimate reasons for the processing, or the person concerned submits an objection to the processing in accordance with Art. 21 (2) GDPR / DSGVO.
- The personal data were processed illegitimate.
- The deletion of personal data is required to fulfill a legal obligation under European law or the law of the Member States to which the responsible party is subject.
- The personal data were collected in the context of offered services by the information society pursuant to Art. 8 para. 1 GDPR / DSGVO.
If one of the above reasons is correct and an affected person wishes to arrange for the deletion of personal data stored by BPM - Berlin Portfolio Management GmbH, they may at any time contact our data protection officer or another employee of the responsible party.
The data protection officer of BPM - Berlin Portfolio Management GmbH or another employee will arrange that the request for deletion be fulfilled immediately.
If the personal data have been made public by BPM - Berlin Portfolio Management GmbH and if our company is responsible for deleting personal data as the person responsible pursuant to Art. 17 para. 1 GDPR / DSGVO, BPM - Berlin Portfolio Management GmbH shall apply technology and implementation costs in appropriate measures, including technical means, to inform other data controllers processing the published personal data that the person concerned has deleted all links to such personal data from those other data controllers or has requested copies or replicas of such personal data, unless the processing is required. The data protection officer of BPM - Berlin Portfolio Management GmbH or another employee will arrange the necessary in individual cases.
7.5 Right to restriction of processing
Any person affected by the processing of personal data has the right, granted by the European directive and regulatory authority, to require the controller to restrict the processing if one of the following conditions applies:
The accuracy of the personal data is contested by the affected person for a period of time that enables the responsible party to verify the accuracy of the personal data. The processing is unlawful, the affected person refuses to delete the personal data and instead requests the restriction of the use of personal data. The responsible party no longer needs the personal data for the purposes of processing, but the affected person requires them to assert, exercise or defend legal claims. The affected person has objection to the processing acc. Art. 21 para. 1 GDPR / DSGVO and it is not yet clear whether the legitimate reasons of the responsible party outweigh those of the affected person.
If one of the above-mentioned requirements is met and an affected person wishes to request the restriction of personal data stored by BPM - Berlin Portfolio Management GmbH, it may at any time contact our data protection officer or another employee of the responsible party. The data protection officer of BPM - Berlin Portfolio Management GmbH or another employee will initiate the restriction of processing.
7.6 Notification obligation in connection with the correction or deletion of personal data or the restriction of processing
Any affected person shall have the right granted by the European legislator and regulator to be informed by the responsible party of the recipients to whom the personal data of the affected person have been disclosed, if he / she so requests.
The responsible party shall inform all recipients who have been disclosed personal data of the affected person of any correction or deletion of personal data or a restriction of processing under Article 16, Article 17 paragraph 1 and Article 18 GDPR / DSGVO, unless this proves to be impossible or is associated with a disproportionate effort.
7.7 Right to data portability
Any person affected by the processing of personal data shall have the right conferred by the European legislator and regulator to obtain the personal data concerning him / her provided to a responsible party by the affected person in a structured, common and machine-readable format. It also has the right to transfer this data to another person responsible without hindrance by the responsible party to whom the personal data was provided, provided that the processing is based on the consent pursuant to Art. 6 (1) (a) GDPR / DSGVO or Art. 9 Abs 2 (a) of the GDPR / DSGVO or on a contract pursuant to Article 6 (1) (b) of the GDPR / DSGVO and processing by means of automated processes, unless the processing is necessary for the performance of a task of public interest or in the exercise of public authority, which has been assigned to the responsible party.
Furthermore, in exercising their right to data portability under Article 20 (1) of the GDPR / DSGVO, the affected person has the right to obtain that the personal data are transmitted directly from one responsible party to another, insofar as this is technically feasible and if so this does not affect the rights and liberties of others.
In order to assert the right to data portability, the affected person may at any time contact the data protection officer appointed by BPM - Berlin Portfolio Management GmbH or another employee.
7.8 Right to object
Any person affected by the processing of personal data shall have the right, conferred by the European legislator and regulator, for reasons arising from its particular situation, to object to the processing of personal data relating to Article 6 (1) (e) or (f) GDPR / DSGVO. This also applies to profiling based on these provisions.
BPM - Berlin Portfolio Management GmbH will no longer process your personal data in the event of an objection, unless we can prove that there are compelling reasons for processing which exceed the interests, rights and freedoms of the affected person, or the processing serves the purpose of assertion, exercise or defense of legal claims.
If BPM - Berlin Portfolio Management GmbH processes personal data in order to operate direct advertisement, the affected person has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to the profiling, as far as it is associated with such direct advertisement. If the affected person objects to BPM - Berlin Portfolio Management GmbH for the purposes of direct advertisement, BPM - Berlin Portfolio Management GmbH will no longer process the personal data for these purposes.
In addition, the affected person has the right to object to the processing of personal data for reasons arising from his / her particular situation, for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para 1 GDPR / DSGVO. Objections shall be lodged unless such processing is necessary to fulfill a task of public interest.
In order to exercise the right to object, the affected person can directly contact the data protection officer of BPM - Berlin Portfolio Management GmbH or another employee. The affected person is also free, in the context of the use of information society services, notwithstanding Directive 2002/58 / EC, to exercise its right of opposition through automated procedures using technical specifications (Article 21 GDPR / DSGVO).
7.9 Automated decisions in individual cases including profiling
Any person affected by the processing of personal data shall have the right, as granted by the European legislator and regulator, not to be subject to a decision based solely on automated processing, including profiling, which has a legal effect on it or, in a similar manner, significantly affects it; unless the decision is necessary for the conclusion or performance of a contract between the person concerned and the responsible party, or is permitted by European Union or Member State legislation to which the controller is subject, and that legislation is adequate to safeguard rights and liberties and the legitimate interests of the affected person or with the express consent of the affected person.
If the decision to conclude or fulfill a contract between the person concerned and the person responsible is necessary or if it is made with the express consent of the person concerned, BPM - Berlin Portfolio Management GmbH shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the affected person, including at least the right to obtain the intervention of a person by the responsible party, to express his / her own position and to contest the decision.
If the affected person wishes to assert any rights with respect to automated decisions, they may at any time contact our data protection officer or another employee of the responsible party (Article 21 GDPR / DSGVO).
7.10 Right to revoke a data protection consent
Any person affected by the processing of personal data has the right, granted by the European legislator and regulator, to revoke consent to the processing of personal data at any time.
If the affected person wishes to assert their right of withdrawal of consent, they may at any time contact our data protection officer or another employee of the responsible party (Article 7 (3) GDPR / DSGVO).
8. Data protection for applications and in the application procedure
The controller collects and processes the personal data of applicants for the purpose of processing the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant sends appropriate application documents electronically, for example by e-mail, to the controller. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents shall be automatically deleted two months after notification of the decision of refusal, provided that no other legitimate interests of the controller stand in the way of deletion. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
9. Data protection regulations on the use and application of Google Analytics (with anonymization function)
The Google Analytics component is operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
In the event that IP anonymization is activated on these Internet pages, the IP address of the person concerned will be reduced by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to Google servers in the USA and only shortened there. IP anonymization is active on these Internet pages. On behalf of the person responsible for this website, Google will use this information to evaluate the use of the Internet pages, to compile reports on the activities on the Internet pages and to provide the person responsible with further services associated with the use of the Internet pages.
The IP address transmitted by an Internet browser within the scope of Google Analytics is not merged with other Google data. The person concerned can prevent the storage of the cookies by an appropriate setting in their Internet browser software. However, BPM - Berlin Portfolio Management GmbH points out to the user that in this case he may not be able to use all functions of these Internet pages in full. The person concerned can also prevent Google from collecting the data generated by the cookie and relating to their use of the website (including their IP address) and from processing this data by Google by downloading and installing the Internet browser extension available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on the use of data for advertising purposes by Google, setting and objection possibilities can be found on Google's websites:
https://www.google.com/intl/de/policies/privacy/partners/ ("Use of data by Google when using our partners' websites or apps"),
http://www.google.com/policies/technologies/ads ("Use of data for advertising purposes"),
http://www.google.de/settings/ads ("Manage information Google uses to show you advertisements") and
http://www.google.com/ads/preferences/ ("Determine what ad Google shows you").
10. Legal basis of the processing
Article 6 para. 1 lit. a GDPR / DSGVO serves BPM - Berlin Portfolio Management GmbH as a legal basis for processing transactions for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the person concerned is a party, as is the case for example with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Article 6 para. 1 lit. b GDPR / DSGVO. The same applies to such processes that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services.
If our company is subject to a legal obligation which requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Article 6 para. 1 lit. c GDPR / DSGVO.
In rare cases, the processing of personal data may become necessary to protect the vital interests of the person concerned or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. Processing would then be based on Article 6 para. 1 lit. d of the GDPR / DSGVO.
Ultimately, processing operations could be based on Article 6 para. 1 lit. f GDPR / DSGVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the person concerned do not prevail. Such processing procedures are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the person concerned is a customer of the person responsible (recital 47, second sentence, GDPR / DSGVO).
11. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 para. 1 lit. f GDPR / DSGVO (see above), it is in our legitimate interest to conduct our business for the well-being of our employees and our shareholders.
12. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide them
We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may result from contractual regulations (e.g. information on the contractual partner). In some cases it may be necessary for a contract to be concluded that a person concerned provides us with personal data which we subsequently process. For example, the person concerned is obliged to provide us with personal data if our company enters into a contract with him/her. Failure to provide personal data would mean that the contract could not be concluded. Before the person concerned provides personal data, he or she can contact one of our employees. Our employee will inform you on a case-by-case basis whether the provision of personal data is required by law or contract or required for the conclusion of a contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.
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Tel.: +49 30 236237-0
Fax: +49 30 236237-37