Legal notices

Cookies

This website uses cookies. We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website.

Cookies are small text files that can be used by websites to make a user's experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Your consent applies to the following domains: www.hal-privatbank.com

Cookie declaration last updated on 13.11.21 by Cookiebot:

Web Tracking

Privacy policy when using Google reCAPTCHA

We use the Google service reCaptcha to determine whether a human or a computer is making a certain entry in our contact or newsletter form. Google uses the following data to check whether you are a human or a computer: IP address of the terminal device used, the website that you visit with us and on which the captcha is embedded, the date and duration of the visit, the recognition data of the browser and operating system type used, Google account if you are logged in to Google, mouse movements on the reCaptcha areas and tasks that require you to identify images. The legal basis for the data processing described is Art. 6 (1) lit. f of the General Data Protection Regulation. There is a legitimate interest on our part in this data processing to ensure the security of our website and to protect us from automated entries (attacks).

Data protection provisions about the application and use of Matomo (with anonymization function)

This website uses the web analysis service software Matomo (www.matomo.org, formerly Piwik), a service of InnoCraft Ltd. 150 Willis St, 6011 Wellington, New Zealand, to collect and store data based on our legitimate interest in statistical analysis of user behavior for optimization and marketing purposes pursuant to Art. 6 Para. 1 letter f DSGVO. Pseudonymised user profiles can be created and evaluated from this data for the same purpose. Cookies may be used for this purpose. Cookies are small text files that are stored locally in the cache of the visitor's Internet browser. The cookies enable, among other things, the recognition of the Internet browser. The data collected with Matomo technology (including your pseudonymised IP address) is processed on our servers. The information generated by the cookie in the pseudonymous user profile is not used to personally identify the visitor to this website and is not combined with personal data about the bearer of the pseudonym.

Further information and Matomo's current privacy policy can be found at https://matomo.org/privacy/  

Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/  and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Digital Marketing

Use of CleverReach for Email Newsletter Distribution

We utilize CleverReach software for the distribution of our email newsletters, a service provided by CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany. CleverReach is a service provider that assists us in efficiently and securely distributing our newsletters. To deliver our newsletter to you, we collect your email address and, if necessary, additional data required for distribution, such as your name.

CleverReach exclusively stores the collected data on servers located within the European Union, thereby ensuring an adequate level of data protection. We have entered into a data processing agreement with CleverReach to guarantee that your data is processed in compliance with applicable data protection regulations.

The purpose and nature of data collection for newsletter distribution are to provide you with regular updates on our offers, promotions, and news that may be of interest to you. Your data will be stored as long as you remain subscribed to the newsletter.

You have the right to withdraw your consent to receive the newsletter at any time. Each newsletter contains an unsubscribe link for this purpose, or you can directly inform us of your wish to revoke your consent via email. After unsubscribing from the newsletter, your data submitted for that purpose will be deleted, unless there is a legal obligation to retain it.

As a data subject, you have the right to request information about the data we have stored about you, as well as the right to rectification, deletion, or restriction of processing. If you have any questions about the collection, processing, or use of your personal data, or if you wish to request access, rectification, restriction of processing, or deletion of your data, please contact our data protection officer at datenschut@hal-privatbank.com

Privacy Policy for the use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet site — which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

The data controller has integrated Facebook Remarketing services on this website. Facebook Remarketing is a feature that enables a company to display advertisements to Internet users who have previously been on the company's website. The integration of Facebook Remarketing therefore allows a company to create user-related advertisements and, as a result, to display advertisements of interest to the Internet user. 

If you are a Facebook member and do not want Facebook to collect information about you through our online services and link it to your Facebook member information, you must log out of Facebook and delete your cookies prior to using our online services. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings or via the US page aboutads.info or the EU page youronlinechoices.com. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

Data protection provisions about the application and use of Google Remarketing

On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise's Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

Data protection provisions about the application and use of Google-AdWords

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages were called up on our website.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

Data protection provisions about the application and use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy.

Data protection provisions about the application and use of Twitter

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 280 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

Data protection provisions about the application and use of Xing

On this website, the controller has integrated components of XING. XING is an Internet-based social network that enables users to connect with existing business contacts and to create new business contacts. The individual users can create a personal profile of themselves at XING. Companies may, e.g. create company profiles or publish jobs on XING.

The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a XING component (XING plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding XING component of XING. Further information about the XING plug-in the may be accessed under https://dev.xing.com/plugins. During the course of this technical procedure, XING gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on XING, XING detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the XING component and associated with the respective XING account of the data subject. If the data subject clicks on the XING button integrated on our Internet site, e.g. the "Share"-button, then XING assigns this information to the personal XING user account of the data subject and stores the personal data.

XING receives information via the XING component that the data subject has visited our website, provided that the data subject is logged in at XING at the time of the call to our website. This occurs regardless of whether the person clicks on the XING component or not. If such a transmission of information to XING is not desirable for the data subject, then he or she can prevent this by logging off from their XING account before a call-up to our website is made.

The data protection provisions published by XING, which is available under https://www.xing.com/privacy, provide information on the collection, processing and use of personal data by XING. In addition, XING has published privacy notices for the XING share button under https://www.xing.com/app/share?op=data_protection.

Data protection provisions about the application and use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

Privacy policy regarding the use of Calendly

The data controller has integrated Calendly on this website. Calendly is a cloud application that offers digital scheduling as a service. Through the secure integration of various calendar providers, the platform enables seamless planning of meetings, including checking availability.

The operating company of the services is Calendly, 1315 Peachtree St NE, Atlanta, GA 30309.

To enable digital appointment scheduling, Calendly automatically collects information about users of the platform, including appointments, email accounts and invoices. At https://calendly.com/pages/privacy you can find out what data is collected and how Calendry deals with it.

The data security regulations published by Calendly, which are callable under https://calendly.com/pages/privacy, give information about the collection, processing and use of personal data by Calendly. Furthermore, Calendly has published further information on compliance with the DSGVO at https://help.calendly.com/hc/en-us/articles/360007032633-GDPR-FAQs.

Data protection regulations for the use and application of telephone, web and video conferences as well as digital invitation management

We process personal data which we have received from you in the context of telephone, web and video conferences and digital invitation management. 

Relevant personal data are, for example, contact data such as title, name, address, telephone number and/or e-mail address. The data serves the purpose of establishing contact with you and enabling you to participate in the services mentioned.

Within our company, those departments that need your data to fulfill the aforementioned purposes will have access to them. If necessary, service providers and vicarious agents employed by us may also receive data for these purposes if they maintain the confidentiality of the data.

Data are not transferred to locations in countries outside the European Union or the European Economic Area (EEA), i.e. to so-called third countries.

We process and store your personal data for the duration of the use of the aforementioned purposes. 

There is no obligation to provide your personal data for the aforementioned purpose.

An automated decision making or profiling (automated analyses of personal data under evaluation of personal aspects) does not take place.

The provider responsible for our telephone, web and video conferences and digital invitation management is Jürgen Dietl Medientechnik GmbH, Parkstraße 4, D-85646 Purfing/Vaterstetten, https://www.dietl-medientechnik.de/verleih-kontakt/impressum/

Legal Basis

Legal Basis, Sources and Purposes of Data Processing

We process your personal data under the relevant data protection regulations based on the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act [Bundesdatenschutzgesetzes (BDSG)], the Insurance Contract Act [Versicherungsvertragsgesetz (VVG)], and other relevant pieces of national legislation.

We process personal data which we receive from our customers, our business partners and interested individuals in the context of our business relationship. Insofar as doing so is necessary for providing our service, we also process personal data which we permissibly obtain from publicly accessible sources (such as land registries, commercial and association registers, press, Internet) or which is legitimately transferred to us by other companies of the Hauck Aufhäuser Lampe Group or by other third parties.

Relevant personal data includes personal details (name, address and other contact details, date and place of birth, as well as nationality), legitimization information (e.g. identification data) and authentication data (e.g. specimen signature). Additionally, this can also be order data (e.g. payment order), details arising from the fulfillment of our contractual obligations (e.g. turnover information in payment transactions), information about your financial situation (e.g. creditworthiness information, scoring / rating data, source of assets), advertising and sales data, documentation data (e.g. suitability statement) and other data which is comparable to the aforementioned categories.

We process personal data

a) to Fulfill Contractual Obligations (Art. 6, Para. 1 b) of the GDPR)

Data is processed for the purpose of conducting banking transactions and providing financial services in the context of implementing our contracts with our customers and business partners or to implement pre-contractual measures on request.

The purposes of data processing are primarily based on the specific product (e.g. account, custodian account, credit) and may include the likes of requirements analyses, consulting and the performance of transactions. Please refer to the relevant contractual documents and the terms of business for further details on the purposes of data processing.

b) in the Context of Balancing of Interests (Art. 6, Para. 1 f) of the GDPR)

Where necessary, we process your data beyond the actual fulfillment of the contract to protect either our or third parties’ legitimate interests.

Examples:

1. Consultation of and data exchange with credit agencies to determine credit and default risks in the lending business
2. Examination and optimization of needs analysis procedures for the purposes of addressing customers directly
3. Advertising or market and opinion research, if you have not objected to such use of your data
4. Assertion and defense of legal claims
5. In the context of legal disputes
6. Ensuring the bank’s IT security and IT operations
7. Business management and further development measures
8. In the context of services and products
9. Risk management within the H&A Group

c) based on Your Consent (Art. 6, Para. 1 a) of the GDPR

If you have granted us consent to process personal data for specific purposes (e.g. disclosure of data within the Group, eMail contact details for marketing purposes), the lawfulness of such processing based on your consent is given. You can revoke the consent you granted at any time.

d) based on Legal Requirements (Art. 6, Para. 1 c) of the GDPR) or in the Public Interest (Art. 6, Para. 1 e) of the GDPR)

We as a bank are also subject to various legal obligations, i.e. legal requirements (e.g. the German Money Laundering Act, the German Securities Trading Act, taxation laws, the German Banking Act) and regulatory requirements (e.g. the European Central Bank, the European banking regulator). For the purposes of processing, these requirements include identity and age checks, fraud and money laundering prevention, credit assessments, the fulfillment of monitoring and reporting obligations under fiscal law, and the assessment and management of risks within both the bank and the H&A Group.

Notice on the processing of personal data pursuant to the EU Money Transfer Regulation

The "Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds" (EU Money Transfer Regulation) serves the purpose of preventing, detecting and investigating money laundering and terrorist financing in money transfers. It obliges the bank to verify and transmit information on the payer (payer) and the payee (payee) when executing transfers of funds. This information consists of the name and customer ID of the payer and payee and the payer's address. For transfers of funds within the European Economic Area, the forwarding of the payer's address may be waived initially, but if necessary this information may be requested from the payee's payment service provider. When providing name and, if applicable, address, the bank uses the data stored in its systems to comply with the legal requirements. The regulation ensures that it is always possible to clearly determine who the payer and payee are from the payment transaction data records themselves. This also means that the bank must verify payment data, answer queries from other credit institutions regarding the identity of the payer or payee, and make this data available to the relevant authorities upon request.

Obligation to Provide Data

In the context of our business relationship, you must provide such personal data which is required for the establishment and implementation of a business relationship as well as the fulfillment of the associated contractual obligations, or such personal data which we are legally obligated to collect. Without this data, we shall generally be unable to conclude or perform the contract with you. In particular, according to regulations under money laundering legislation, we are obligated to identify you using your identity documents before establishing the business relationship, and to collect and record your name, place and date of birth, nationality, address and identification data in this regard. So that we can comply with this legal obligation, you must provide us with the necessary information and documents under the German Money Laundering Act and immediately notify us of any changes during the course of the business relationship. If you do not provide us with the necessary information and documents, we may not establish or continue the desired business relationship.

Categories of Recipients of Personal Data

Within the H&A Group, those parties who require access to your data to meet our contractual and legal obligations receive access to your data. The service providers and vicarious agents we engage may also receive data from us for these purposes, as long as they maintain banking secrecy. These include companies operating, for example, in the categories of credit services, IT services, logistics, printing services, telecommunications, debt collection, advisory services and consulting, as well as sales and marketing.

With regard to the disclosure of data to recipients outside of our bank, it should be noted first of all that we as a bank are obligated to maintain secrecy concerning all customer-related facts and assessments which we become aware of.

We may only disclose information about you if we are required to do so by law, if you have given your consent to this effect, or we are authorized to disclose banking affairs. In these circumstances, recipients of personal data may be:

1. Public authorities and institutions (e.g. European Banking Authority, European Central Bank, financial authorities, law enforcement authorities), if a legal or official obligation exists.
2. Other credit and financial service institutions or similar establishments to which we transfer personal data for the purpose of implementing the business relationship with you (depending on the contract, these may be correspondent banks, custodian banks, investment companies, stock exchanges and credit agencies).
3. Other companies within the Group for the purposes of risk management based on a legal or official obligation. Other data recipients may be those parties for whom you have given us your consent to data transfer or for whom you have released us from our obligation to maintain banking secrecy under the agreement or consent.

If we transfer personal data to service providers outside of the European Economic Area (EEA), such transfer to the third country shall only take place insofar as the European Commission has confirmed an appropriate level of data protection or insofar as other appropriate data protection guarantees (e.g. binding internal data protection regulations or EU standard contractual clauses) exist. Data transfer to parties in states outside of the European Union (“third countries”) takes place insofar as

1. Doing so is necessary to executing your orders or our services (e.g. payment and securities orders),
2. Doing so is stipulated by law (e.g. reporting requirements under fiscal law), or
3. You have given us your consent to this effect.

Furthermore, data transmission in the context of our telephone system support and maintenance cannot be completely excluded, so in individual cases personal data may be transmitted to following countries:

Hong Kong, India, Malaysia, Singapore, USA, UK. 

Data Storage Period

We store personal data for as long as is necessary for performance of the contract. A deviating storage period may result due to legal proof and retention requirements which are regulated in relevant laws and regulations (e.g. in the German Money Laundering Act). The storage periods generally last up to ten years. Despite this, the storage period may be based on the national legal limitation periods, which may last three or up to 30 years.

Your Rights as a Data Subject

You have a right, according to Art. 15 of the GDPR, to request information about the stored personal data concerning you.

Under certain conditions, you can also request that your personal data be corrected according to Art. 16 of the GDPR or deleted according to Art. 17 of the GDPR, for example:

1. If your personal data is no longer needed for the purposes for which it was collected
2. If you revoke your consent and there is no other legal basis
3. If you object to processing and there are no overriding legitimate grounds for processing
4. If your personal data was processed unlawfully
5. If your personal data has to be deleted to comply with legal requirements.

Please bear in mind that a right to deletion depends on whether legitimate grounds for data processing exist.

You may also have a right to restriction of processing of your data according to Art. 18 of the GDPR, for example:

1. If you dispute the accuracy of your personal data and we had the opportunity to check the accuracy of the same
2. If processing is not lawful and you request restriction of use instead of deletion
3. If we no longer need your data for the purposes of processing, but you require the same to assert, exercise or defend legal claims
4. If you have filed an objection, as long as it has not yet been determined whether your interests take precedence.

If we process your data for statistical purposes, you can object to such processing on grounds relating to your particular situation according to Art. 21, Para. 6 of the GDPR.

You may also be entitled to a right to release of the data you provided in a structured, common and machine-readable format.

In individual cases, you may not be satisfied with our response to your request. In this case, you are entitled to lodge a complaint with H&A’s data protection officer and the responsible data protection supervisory authority.

Automated Decision-Making

In some cases, we use the technical features of automated decision-making so that we can offer our services and products quickly and easily. If we do so in your situation, we inform you of this process – if this is prescribed by law. We sometimes process your data automatically with the aim of assessing certain personal aspects (profiling). This applies, for example, to the following cases:

1. Due to legal and regulatory requirements, we are obligated to combat money laundering, terrorist financing and other criminal activities which could put assets at risk. Data evaluations (including in payment transactions, etc.) are also carried out. These measures are implemented for your protection in particular.
2. Through targeted marketing, we only want to make you offers which are tailored to your needs.
3. We use rating procedures to assess the creditworthiness of our potential customers. The aim of the rating procedures is to systematically process information so that we can make decisions on a debtor’s creditworthiness situation. Based on historical rating and loss information, statistical probability statements are made concerning the extent of a debtor’s default over time which help us make a decision.

Right of Objection

a) Individual Right of Objection

You have the right on grounds relating to your particular situation to object to the processing of your personal data. The precondition for this is that data is being processed in the public interest or based on a balancing of interests. This also applies to profiling. If you object, we shall no longer process your personal data, unless we can demonstrate compelling and legitimate grounds for processing such data which outweigh your interests, rights and freedoms, or unless your personal data is being used to assert, exercise and defend legal claims.

b) Objection to Processing of your Data for our Direct Advertising Purposes

In individual cases, we use your personal data for our direct advertising purposes. You have the right, at any time, to object to this practice; this also applies to profiling if it is in conjunction with such direct advertising. If you object, we shall no longer process your personal data for these purposes. You can object in an informal manner, where possible by contacting:

Hauck Aufhäuser Lampe Privatbank AG
Data Protection Officer
Kaiserstraße 24
60311 Frankfurt am Main

eMail: HAL@2B-Advice.com