As the operator of the Internet presence under “www.astoriuscapital.com”, we place great value on protecting your private and personal sphere.
We collect and utilize the personal data of visitors to our website only, provided this is necessary, in order to provide the website as well as our content and services in a functional manner, and to make the use of such more convenient for visitors.
Personal data can normally only be processed with the consent of the visitor. In addition, processing may occur if prior consent cannot be obtained for practical reasons and this processing of data is permitted by law – in particular by the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG 2018).
According to Art. 4 Clause 1 GDPR, “personal data” means any information relating to an identified or identifiable natural person (“data subject”). This includes the name, address, date of birth, email address, and telephone number, for example.
According to Art. 2 Clause 2 GDPR, “processing” means any operation or set of operations which is performed on personal data, whether or not by automated means (such as collection, recording, use, or dissemination).
According to Art. 4 Clause 7 GDPR, “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
We would also like to establish what data is processed when visiting or using our website, for what purpose and on which legal basis this is done, whether there is an obligation to provide this information, and how long this data is stored (Clause 2).
Furthermore, we would like to explain to what degree data is transmitted, which security measures are maintained, and whether there is an automatic decision-making process (Clauses 3 to 6). Finally, we would like to inform you of your rights with respect to the processing of your personal data (Clause 7).
1. Name and contact information of the controller
The controller for data processing when visiting or using this website is:
Astorius Consult GmbH
Neuer Wall 41
20354 Hamburg, Germany
Tel. +49 40 468 99 13-0
Fax +49 40 468 99 13-99
Data protection officer: Julien Zornig
2. Data processing when visiting and using our website
2.1 Saving access data to log files
Generally speaking, you may visit and use our website without providing personal information. When visiting our website, the Internet browser you use automatically transmits certain pieces of access data to the server provided. This concerns the following information:
- IP address of the computer making the request
- browser used as well as the version and language
- operating system of the computer making the request
- date and time of access
- name and URL of the website or file requested
- website from which access is made
- access status/http status code
- quantity of data transmitted
Scope and purpose of data processing:
This data is temporarily saved to a so-called log file. First, this serves the purpose of ensuring system security and stability on a permanent basis and enabling th technical administration of such, thus guaranteeing the error-free establishment of connections and operation of our website, and that our website is convenient to use. Additionally, this data is evaluated internally for administrative and statistical purposes in order to improve our online offer. We do not combine this data with other data or data sources that would make it possible to draw conclusions about your person.
The legal basis for this processing is Art. 6 Para. 1 Clause 1 (f) of the GDPR. With this data processing, we have a legitimate interest in maintaining the operational security of our website in order to provide this website and the information contained therein in an error-free and convenient manner.
This data is erased as soon as it is no longer required to achieve the aforementioned purposes of collection. In the event that data is collected in order to provide our website, this data will be erased when the respective session is ended. Otherwise, this data is erased regularly after seven days at the latest. Storage beyond this period is possible; in this case, however, the IP address will be deleted or distorted so that it is no longer possible to assign it to a natural person.
Scope and purpose of data processing and storage duration:
When you visit our website, so-called cookies will also be saved to your end device or hard drive. Cookies are text or information files that your Internet browser saves automatically to your end device when calling up our website. They include specific data or settings that are exchanged between your Internet browser and our system. This primarily concerns information on which subpages of our Internet offer are most commonly requested.
The information generated or transmitted using cookies is not personal data. Therefore, you cannot be personally identified using this information. Cookies cannot execute programs or damage your end device. On the contrary, cookies serve to create statistics on the use of our website and to optimize such.
In addition, we use temporary cookies, which are saved to your end device for a certain period of time in order to optimize the user-friendliness of our website. If you visit our website again in order to make use of our services, we will automatically detect that you have already visited and which information and settings you have provided so that you do not need to enter them again. The following information is stored or transmitted using these cookies:
The visitor data collected in this way is pseudonymized via technical precautions. This data is not saved together with other personal data on the visitor. It is therefore no longer possible to assign the data to a visitor.
The legal basis for this processing is Art. 6 Para. 1 Clause 1 (f) of the GDPR. With this data processing, we have a legitimate interest in optimizing the user-friendliness of our website.
Option to refuse the saving of cookies:
Most Internet browsers automatically accept cookies. You can also use our website without cookies. However, we must point out that you may no longer be able to fully utilize all the services or functions of our website.
If you would like to prevent the use of Flash cookies, you can install the respective add-on for the browser you use, for example “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/en/firefox/addon/betterprivacy).
2.3. Data processing when using our contact form
Scope and purpose of data processing:
You can submit inquiries to us and request informational material using the contact form provided on our website. The data that will be requested from you when doing so includes your first and last name, your telephone number, and your email address. This information is necessary for us to process your inquiry and to be able to contact you. If additional information is required to respond to your inquiry, you will be specifically asked to provide it.
When submitting an inquiry, the user’s IP address as well as the date and time that the contact form is used will also be saved. This serves to prevent the misuse of our services or the data entered and to protocol this contact for purposes of verification.
We will only use the data submitted via the contact form or any other form of contact to respond to your inquiry. We will not pass on this data to third parties either in return for payment or free of charge. Unless you have consented to the further storage and use of your personal data, it will be stored only as long as is necessary to fulfill the purpose of the transmission or as required by statutory regulation (tax and commercial retention periods in particular).
The legal basis for this processing is Art. 6 Para. 1 Clause 1 (f) of the GDPR. We have a legitimate interest in providing our users with a convenient form of contact and in processing the data required to respond to such an inquiry.
This data will be stored only as long as is necessary to process the respective inquiry. In addition, a longer storage may be necessary due to legal obligations, in particular due to commercial or tax-related retention obligations under the Commercial Code (HGB) and the Tax Code (AO), which specify storage for up to ten years. Otherwise, data will be stored for a longer period only if this is necessary to fulfill a contract.
The additional data stored when using the contact form will be deleted following a period of seven days at the latest.
2.4. Data processing for our newsletters
Scope and purpose of data processing:
We offer a newsletter, which is sent by email, in order to inform you about news as well as to promote our own products or services. The newsletter is only sent if you have registered for such over our website or via a link in an email message. When registering for our newsletter, we use the so-called double opt-in process. This means that we will first send you a confirmation email containing a link after entering your email address and ticking the box for the newsletter. If you click on this link, you confirm that you would like to be sent the newsletter and give your consent to receive our newsletter at the email address you entered. We will send our newsletter to your email address only if you have given this confirmation. We save your information only for the purpose of sending you the newsletter.
The only information required to receive the newsletter is your email.
When registering to the newsletter, the user’s IP address as well as the date and time of registration will also be saved. This serves to prevent the misuse of our newsletter or the email provided and to protocol this registration for purposes of verification.
The legal basis for storing email addresses is Art. 6 Para. 1 Clause 1 (a) of the GDPR. Data will only be processed if you have given consent for such for the aforementioned purposes.
You can revoke your consent at any time (each if you have already given consent before the GDPR came into effect). Revoking your consent will apply in the future, meaning that the legality of data processing, which was based on your consent and before its revocation, remains unaffected.
The legal basis for storing the IP address and date and time of login is Art. 6 Para. 1 Clause 1 (f) of the GDPR.
Data processing is necessary to protect our legitimate interest in the error-free use of the newsletter and, in the event of misuse, also to assert, exercise, and defend legal claims. In the event of the misuse of an external email address, this data may also need to be processed to protect the legitimate interests of a third party, namely the owner of the email address entered.
This data is erased as soon as it is no longer required to achieve the respective purposes of collection. Therefore, this data will be saved for as long as you are subscribed to the newsletter.
2.5. Data processing through the use of Google Analytics
The use of Google Analytics is in accordance with the conditions that German data protection supervisory authorities have agreed upon with Google.
Please note that, the extension "_anonymizeIp ()" has been activated by Google Analytics on this website in order to ensure the anonymized collection of IP addresses. As a result, IP addresses are processed in a shortened form. This prevents a direct association with any person (for more: https://support.google.com/analytics/answer/2763052?hl=en-us).
The IP address provided by your browser as part of Google Analytics will not be combined with other Google information.
You can prevent the storage of cookies by configuring your browser accordingly. However, we must point out that, in this case, you may not be able to fully utilize all the functions of this website. You can also prevent the collection of data generated by cookies and related to your use of the website (including your IP address), and the processing of this data on the part of Google, by downloading and installing the browser plug-in available at the link below:
Information on the third-party provider Google:
Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Terms of service:
The legal basis for the aforementioned data processing is Art. 6 Para. 1 Clause 1 (f) of the GDPR. By implementing these measures, we have a legitimate interest in designing and continuously optimizing our website based on the usage analyses conducted. Data is transmitted exclusively in pseudomized form.
On our website, we use a map service from Google Maps under the “Contact” menu option in order to display the route to our facilities and parking options so as to simplify planning and arrival. By using this map, you agree to the collection, processing, and use of the automatically collected data on the part of Google Inc., its representatives, as well as third parties. You can find the Google Maps Terms of Service at Google Maps Terms of Service.
This website contains embedded videos from YouTube, a company of Google Inc., with headquarters in San Bruno, California, USA. When you view these YouTube videos, a connection to the YouTube servers is established. In doing so, your IP address, as well as which specific pages of our Internet presence you visited, will be shared with the YouTube server. If you were previously logged in to your YouTube account, this would allow YouTube to directly associate your surfing behavior with your personal profile. You can prevent YouTube’s ability to assign this behavior by previously logging out of your account. You can find more information on the collection and use of your data on the part of YouTube by viewing their notice on data privacy at www.youtube.com.
3. Obligation or requirement to provide data, necessity to provide for a contract, potential consequences of non-provision
If you would like to subscribe to our newsletter (Section 2.4), you must provide us with your email address. We cannot send you a newsletter without this information.
If you would like to use the contact form provided (see Section 2.3.), you must provide us with the personal data specified there as required information. This information is required to process the inquiry. We cannot process your contact inquiry or registration to an event without providing the information required for such.
4. Data transmission and data recipients
Your data is transmitted to third parties only for the purposes listed in the following.
We disclose your personal data to third parties only
- if you have given consent to such in accordance with Art. 6 Para. 1 Clause 1 (a) GDPR, or
- if, in accordance with Article 6 Para. Clause 1 (f) GDPR, this disclosure is required to assert, exercise, or defend legal claims, and there is no reason to assume that you have an overriding interest in not having your data disclosed, or
- if this disclosure is required by law in accordance with Art. 6 Para. 1 Clause 1 (c) GDPR, or
- if this disclosure is legally permitted and the disclosure is required to fulfill a contract with you in accordance with Art. 6 Para. 1 Clause 1 (b) GDPR.
If you visit our website, data on this visit may be sent to companies located in the USA. This is done for analysis purposes and concerns only anonymous data. You can find more information on this under Section 2.5 regarding the use of the web analysis service Google Analytics.
The European Commission reached an agreement on this in consultation with the USA, (the so-called "EU-US Privacy Shield”) http://eur-lex.europa.eu/homepage.html?locale=en.
The complete English text of the agreement is currently available at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016D1250&from=EN (as HTML version) or at http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016D1250&from=EN (as a PDF version)
5. Data protection
We are committed to ensuring the security of your data. In order to prevent the loss, misuse, and modification of personal data, we have established corresponding physical, electronic, and administrative processes and adapt these to the current state of technology accordingly. This includes training for staff who have access to personal data.
6. No use of automated decision-making processes including profiling
We do not make use of any so-called profiling or any other decision-making processes that rely solely on automated data processing measures that would have a legal effect on you or substantially affect you in a similar manner.
7. Your rights as a data subject
You have the following rights with regard to processing your personal data:
- Right of access (Art. 15 GDPR)
You have the right to obtain information on your personal data that is being processing by us. In particular, you may request information on the purpose of processing, the categories of the personal data, the categories of recipients to whom your data was or will be made available, the planned storage duration, the existence of a right to rectification, to erasure, to the restriction of processing, or the right to object, the existence of a right to appeal, the source of your data, provided it was not collected by us, as well as the existence of an automated decision-making process including profiling and any meaningful information on your particular details.
- Right to rectification (Art. 16 GDPR)
You have the right to request the immediate rectification of your personal data that was stored incorrectly by us, or to request the completion of such, provided the data was stored by us in an incomplete fashion.
- Right to erasure (Art. 17 GDPR)
You have the right to request the erasure of your personal data that we have stored, provided the processing of such is necessary to exercise the right of freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims.
- Right to restriction of processing (Art. 18 GDPR)
You have the right to request the restriction of processing of your personal data, provided you dispute the correctness of this data, provided this processing is unlawful but you refuse erasure of this data, provided we no longer need this data but you need it to assert, exercise, or defend against legal claims, or provided you have objected to processing in accordance with Art. 21 GDPR.
- Right to data portability (Art. 20 GDPR)
You have the right to receive your personal data that you provided to us in a structured, commonly used, and machine-readable format, or to request submission of the data to another controller.
- Right to revoke consent given at any time (Art. 7 Para. 3 in connection with Art. 6 Para. 1 Clause 1 (a) or Art. 9 Para. 2 (a) GDPR)
You have the right to revoke consent given to us at any time. As a result, we can not continue to process data related to this consent in the future, unless this processing can be supported by a different legal basis.
- Right of appeal to a supervisory authority (Art. 77 GDPR in connection with § 19 BDSG 2018)
You have the right to appeal to a supervisory authority if you are of the view that processing your personal data violates the GDPR. Generally speaking, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
- Right to object (Art. 21 GDPR)
If we process your personal information for legitimate interests, you may object to this for reasons arising from your particular situation. You can also object to the processing of personal data if this is done for purposes of direct advertising.