Data protection
1. Controller and Data Protection Officer
Paul Richter & Alexander Wolf - meinenergiehaus.info
Lößnitzer Straße 9
08280 Aue
Telefon: 01764 6682895
E-Mail: Paul.Richter@dvag.de
E-Mail: Wolf.Alexander@dvag.de
2. General Information on Data Processing and Your Rights
2.1. Applicable Legal Bases for Data Processing
Unless the legal basis is expressly stated otherwise in this Privacy Policy, the following legal bases apply:
If we obtain your consent for the processing of your personal data, Article 6(1)(a) and Article 7 GDPR constitute the legal basis for processing.
If the processing of data is necessary for the performance of our services and the implementation of contractual measures, as well as for responding to inquiries, Article 6(1)(b) GDPR constitutes the legal basis.
If data processing is necessary to comply with a legal obligation, Article 6(1)(c) GDPR constitutes the legal basis. Examples include compliance with statutory retention periods under commercial law or tax-related retention obligations.
If the processing of personal data is necessary to protect a legitimate interest of our company or a third party, Article 6(1)(f) GDPR constitutes the legal basis.
Legitimate interests include, in particular, ensuring IT security and IT operations, asserting legal claims and defending against legal disputes, creating user statistics, advertising our own services and products as well as those of companies within the DVAG Group, our financial advisors and our product partners, and conducting market and opinion research, provided that these interests do not conflict with the rights of the data subjects.
2.2. Your Rights
You have the right to:
Access your personal data pursuant to Article 15 GDPR
Rectification pursuant to Article 16 GDPR
Erasure pursuant to Article 17 GDPR
Restriction of processing pursuant to Article 18 GDPR
Data portability pursuant to Article 20 GDPR
The rights to access and erasure are subject to the restrictions set out in Sections 34 and 35 of the German Federal Data Protection Act (BDSG).
In addition, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Article 77 GDPR in conjunction with Section 19 BDSG.
You may withdraw your consent to the processing of personal data at any time with effect for the future.
2.3. Data Retention Period
Unless otherwise stated in this Privacy Policy, personal data is stored only for as long as necessary to fulfill the respective purpose or our contractual or legal obligations.
We are subject to various statutory retention and documentation obligations. These arise in particular from the German Commercial Code (HGB), the German Fiscal Code (AO), the Money Laundering Act (GwG), and the German Regulation on Financial Investment Brokerage and Advisory Services.
The retention periods prescribed by law may be up to 10 years.
2.4. Disclosure of Personal Data
If we transfer personal data to other persons or companies, this is done only on the basis of your consent, a legal authorization, a legal obligation — for example, to public authorities and institutions such as supervisory or tax authorities — or on the basis of a data processing agreement pursuant to Article 28 GDPR.
Further categories of recipients can be found in this Privacy Policy, particularly under Section 3.
2.5. Transfer of Data to Third Countries
Personal data is transferred outside the European Economic Area (EEA) only where the European Commission has confirmed that the third country provides an adequate level of data protection pursuant to Article 44 et seq. GDPR, or where other appropriate safeguards for the protection of personal data are in place.
2.6. Automated Decision-Making
No automated decision-making or profiling takes place as part of this website.
3. Further Information on Data Processing
3.1. Cookies
Our website uses cookies. These are small data packages that are stored on the customer's device.
In addition to so-called session cookies, which are automatically deleted when you log out or close your browser, we also use so-called persistent cookies, which recognize returning users. These cookies are automatically deleted after a specified period of time.
You can object to the use of cookies at any time by changing the corresponding settings in your internet browser. Cookies that have already been stored can also be deleted at any time.
If cookies are disabled, some functions of our website may no longer be fully available.
The legal basis for setting cookies is the protection of the legitimate interests described above pursuant to Article 6(1)(f) GDPR.
3.2. Collection of General Data and Creation of Log Files
When you access our website, general data and information is automatically collected and stored in a server log file.
The following data may be collected:
Information about the browser type and version
Information about the user's operating system
Information about the user's internet service provider
The user's or accessing system's Internet Protocol address (IP address)
Date and time of access
The website from which you accessed our website (referrer URL)
Websites accessed by the user's system through our website
The processing of this data serves to provide our website, ensure the functionality of our information technology systems and optimize our website.
These data and information are evaluated statistically using anonymous data, with the aim of ensuring data protection and data security.
The log-file data is always stored separately from any other personal data collected and is not combined with such data.
The data is automatically deleted after the purpose for which it was collected has been fulfilled.
The legal basis for the temporary processing of this data is the protection of the legitimate interests described above pursuant to Article 6(1)(f) GDPR.
3.3. Collection and Analysis of User Actions / Personalized Content
Where you have given your consent pursuant to Article 6(1)(a) GDPR, we collect information about your user actions when you visit our website and store this information in a pseudonymized user profile.
For this purpose, we use functions of Salesforce Marketing Cloud, where the pseudonymized profiles are also stored.
This includes, for example:
Information about the pages you visit
Click paths
Other interactions on our website
We use these pseudonymized profiles to provide you with personalized content tailored to your product interests and to improve your experience on our website.
You may withdraw your consent to the collection and analysis of your data at any time under “Edit Cookies.”
3.4. Contact Form and Email Contact
Our website provides a contact form and an email address through which you can contact us electronically.
If you use one of these channels and contact us, the personal data you provide will be automatically stored.
The storage and processing of this data is carried out exclusively for the purpose of processing your inquiry and subsequently communicating with you.
Your data will generally not be disclosed to third parties.
An exception applies if your inquiry concerns a financial advisor of our company and your data must be forwarded to that advisor in order to process your inquiry.
The data you provide will be deleted once the matter has been completed, unless statutory or contractual retention periods prevent deletion.
In such cases, the data subject to retention obligations will be deleted after the applicable retention period has expired.
The legal basis for processing the data is Article 6(1)(f) GDPR.
3.5. Newsletter and Email Advertising
Our newsletters provide you with information about current products and news.
To register, it is generally sufficient to provide your email address. Providing additional information is voluntary.
If you register for our newsletter, we use your email address and, where applicable, any other information you voluntarily provide to us for sending the newsletter.
When you successfully register for the newsletter, we also store the date of your registration and, where registration takes place via our website, your IP address.
This storage serves as proof in the event that a third party misuses an email address and registers for the newsletter without authorization.
If you provide additional data when registering, we process this information for the purpose of sending the newsletter using Salesforce Marketing Cloud and Salesforce Sales Cloud.
The newsletter is sent on the basis of your consent pursuant to Article 6(1)(a) GDPR.
If you have provided consent for advertising our own or similar products or services, we may also use your data to advertise our goods and services on the basis of our legitimate interests pursuant to Article 6(1)(f) GDPR, where legally permitted, for example in the case of advertising to existing customers, provided that you have not objected.
We also store the data you provide during registration on the basis of our legitimate interests in order to be able to demonstrate your consent where necessary.
You may unsubscribe from the newsletter at any time using the unsubscribe link contained in every newsletter.
Alternatively, you may contact us directly using the postal or email address stated above.
After unsubscribing, we may retain the email addresses that have been removed from the mailing list for up to three years in order to demonstrate consent previously given.
To continuously optimize our newsletter and provide you with a user-oriented and secure newsletter, we analyze certain user activities.
We measure how often the newsletter is opened and which links users click.
For this purpose, the newsletter contains a so-called web beacon or tracking pixel, a file that is retrieved from our server when the newsletter is opened.
Technical information is also collected, such as browser type, operating system and the time at which the newsletter was accessed.
It can also be determined whether and when a newsletter was opened and which links were clicked.
This information helps us understand the usage and reading habits and interests of our subscribers, allowing us to adapt the content and improve the user experience.
The analysis is carried out on the basis of your consent or, where applicable, on the basis of our legitimate interests in providing a user-friendly and informative newsletter.
In some cases, we may make the receipt of free services dependent on consent to receive the newsletter or other emails, for example participation in certain promotions.
3.6. Use of Salesforce Marketing Components
Data that you provide when visiting our website, for example through contact forms or when registering for our newsletter, is stored in the Salesforce Sales Cloud, a platform operated by Salesforce.com Germany GmbH, Erika-Mann-Straße 31, 80636 Munich, Germany.
We also use Salesforce Marketing Cloud to send newsletters and mailings, provide personalized content on our websites and conduct campaigns on social networks.
With Salesforce, we have entered into a data processing agreement pursuant to Article 28 GDPR and agreed on standard contractual clauses.
Salesforce has also entered into binding corporate rules pursuant to Article 47 GDPR, which have been verified by European data protection authorities.
We have taken measures to ensure that data is preferably processed on servers located within the European Union.
Further information can be found on Salesforce's website under its privacy policy.
Despite the measures we have taken, in certain cases personal data may nevertheless be transferred to the parent company of Salesforce.com Germany GmbH, Salesforce Inc., One Market Street, Suite 300, San Francisco, CA 94105, USA, or processed in other non-EU countries.
Salesforce is subject to the standard contractual clauses as part of the EU Standard Contractual Clauses, which are intended to ensure an adequate level of data protection and additional security measures.
If you do not wish to receive personalized content on our websites, you can withdraw your consent at any time under “Edit Cookies.”
3.7. Questions About Your Dream Career
On our website, you can answer our “10 Questions About Your Dream Career.”
The data you provide will be forwarded to the respective financial advisor, whose website contains the 10 questions and where the information may also be stored.
The data will not be disclosed to other groups of people.
As part of the 10 questions, information about your expectations regarding your future professional activities as well as your contact details — such as name, email address and, where applicable, telephone number — will be collected.
The respective financial advisor uses this data to contact you, if desired, and to provide information about various career opportunities related to the financial advisor profession.
The data you provide will be deleted once the process has been completed, unless contractual or statutory retention periods prevent deletion.
Your rights to object and request deletion remain unaffected.
The legal basis is your consent pursuant to Article 6(1)(a) GDPR.
3.8. Use of Adobe Analytics
Our website uses Adobe Analytics (Omniture) and/or the Adobe Marketing Cloud, hereinafter referred to as “Omniture,” a web analytics service provided by Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland.
Omniture enables us to analyze the behavior of visitors and visitor flows on our website.
This allows us to tailor content to demand and identify and resolve problems more quickly.
Omniture stores cookies on your system.
We also ensure through appropriate system settings that the tracking data transmitted to Adobe is anonymized before geolocation takes place.
Anonymization is carried out by replacing the last part of the IP address.
We have also configured server-side settings so that your IP address is anonymized independently for geolocation and reach measurement before processing.
Adobe processes the collected data and information exclusively on our behalf.
The purpose is to analyze user behavior and create anonymized reports and statistics.
The data collected, in particular your IP address, is not combined by Adobe or by us with other personal data.
We use the resulting information to optimize our website.
The legal basis for processing the data is Section 15 (3) of the German Telemedia Act (TMG) and/or Article 6(1)(f) GDPR.
The applicable privacy provisions of Adobe can be found on Adobe's website.
You can prevent cookies from being set through our website by changing the appropriate settings in your internet browser and thereby permanently object to the setting of cookies.
Changing your browser settings can also prevent Omniture from placing a cookie in the information technology system of the person concerned.
Cookies already placed by Omniture can also be deleted at any time using an internet browser or other software.
You also have the option of objecting to the collection of data generated by the Adobe cookie relating to your use of this website and to the processing of this data by Adobe.
To do so, you must use Adobe's opt-out function to set an Opt-Out Cookie.
If the Opt-Out Cookie is deleted from your system after you have objected, you must access the link again and set a new Opt-Out Cookie.
However, setting an Opt-Out Cookie may mean that the websites of the controller can no longer be used to their full extent.
3.9. Use of Google Analytics
Our website uses Google Analytics, an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
Web analytics involves collecting, compiling and analyzing information about the behavior of visitors to websites.
For example, information is collected about which website you came from, which pages you accessed and how long you viewed a subpage.
Cookies are used for this purpose.
Cookies are text files stored on a computer system via an internet browser.
The information collected by the cookie is transmitted to and stored on a Google server in the USA.
This includes, in addition to information about website usage, your IP address.
We use Google Analytics with the extension “anonymizeIP.”
This means that your IP address is shortened and anonymized when you access our website from within member states of the European Union or other states party to the Agreement on the European Economic Area.
The transmitted IP address is not combined with other data held by Google.
The purpose of data processing is to analyze visitor flows and the use of our website.
Google prepares online reports for us on our behalf.
We use the resulting information to optimize our website.
The legal basis is Section 15(3) TMG and/or Article 6(1)(f) GDPR.
You can prevent cookies from being set through our website at any time by changing the corresponding settings in your internet browser.
You can also delete cookies already placed by Google at any time using an internet browser or other software.
3.10. Information on Data Processing in Online Meetings
For online meetings, video conferences or webinars (“online meetings”), financial advisors use the tools “Zoom” or “Microsoft Teams.”
Zoom is a service provided by Zoom Video Communications Ltd., 55 Almaden Boulevard, 6th Floor, San Jose, California 95113, USA.
Microsoft Teams is a service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
The financial advisor who invited you to the respective online meeting is responsible for data processing directly related to conducting the online meeting.
Please refer to the Zoom or Microsoft website, or use the Zoom or Teams app, for more information on who is responsible for data processing.
During an online meeting, participants' personal data may also be processed and, where applicable, stored on Zoom or Microsoft servers insofar as this is part of the communication process.
This includes, in particular:
Metadata, such as IP addresses and device/hardware information
User data, such as usernames and email addresses
Passwords
Text, audio and video data
The legal basis for processing is Article 6(1)(f) GDPR.
The legitimate interest lies in conducting online meetings in an appropriate and efficient manner.
3.11. Recording Obligations Pursuant to Section 18a of the Financial Investment Brokerage Regulation
Companies and persons acting as financial investment brokers on our behalf are required pursuant to Section 18a of the Financial Investment Brokerage Regulation (FinVermV) to record the content of telephone conversations or other electronic communications for evidentiary purposes whenever the communication relates to the brokerage of or advice on financial investments.
This also applies if the telephone conversation or other electronic communication does not result in the conclusion of a contract.
The recordings are automatically deleted after the statutory retention period has expired.
Telephone recording is voluntary. You may object to the recording.
In this case, telephone brokerage or investment advice is excluded.
Within our company, only those departments that require access to the recordings for the purpose of processing have access to them.
We will only disclose recordings to other departments where we are legally required to do so or where this serves the purpose of legal defense.
The legal basis for processing is Article 6(1)(c) GDPR and Section 18a FinVermV.
3.12. Personalized Offers
From time to time, your financial advisor may send you personalized offers that they believe are suited to your interests and needs.
For this purpose, your financial advisor processes your personal data on the basis of legitimate interests pursuant to Article 6(1)(f) GDPR, in order to send you relevant information and offers by post or — provided you have consented — by email.
For this purpose, your financial advisor uses your contact details, such as:
Name
Address
Email address
as well as other information that you or we have provided, such as information about your product interests.
You may object to this use of your data at any time with effect for the future or withdraw previously given consent.
Your objection or revocation can be sent directly to your financial advisor or by email to datenschutz@dvag.com.
Personalized offers can be concluded online. Only you have access to the offer.
If you decide to conclude a contract, we may collect and process additional personal data as part of the relevant service or application process, such as:
Name
Address
Data concerning the insured risk
Payment information
The purpose of processing the data is to arrange insurance and financial products with product partners, prepare applications and carry out the associated pre-contractual measures.
The legal basis is Article 6(1)(b) and (f) GDPR.
Data is only disclosed to the product partner with whom you wish to conclude the contract.
Further information on data processing by us and our financial advisors when arranging insurance and financial products can be found in the relevant data protection information.
3.13. Customer Reviews
If you submit a customer review, we publish your review under your name or, alternatively, under a pseudonym chosen by you.
The data is processed exclusively for the purpose of publishing your review on our websites.
No specific storage period is provided for.
Your review is accessible not only to the financial advisor being reviewed, but also to other visitors to the website.
You may request deletion of your review at any time or object to its processing with effect for the future.
The legal basis for processing is Article 6(1)(f) GDPR.
Our legitimate interest lies in transparency and the formation of opinions.
4. Integration of Third-Party Services and Content (Social Plugins, etc.)
Some of our websites use services and content provided by third parties, particularly so-called social plugins, videos and fonts.
This is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, in providing and processing third-party content, analyzing it, optimizing it and operating our website.
Our websites may therefore integrate services and content from the following third-party providers:
Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA
Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA
YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA
XING AG, Gänsmarkt 43–45, 20354 Hamburg, Germany
Instagram LLC, 1 Hacker Way, Building 14, First Floor, Menlo Park, CA, USA
Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA
For data protection matters outside the USA: LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Where a website uses social plugins, we use the “Shariff” solution to protect your data.
Social plugins are therefore integrated into our website merely as graphics. This means that there is no direct connection to the website of the plugin provider.
If you click on the graphic, you will be redirected directly to the respective provider. Only then will your data be transmitted to the provider.
If you do not click on the graphic, no data is exchanged with the provider of the respective social plugin.
Further information on the use of your data can be found in the respective provider's terms of use and privacy policies.
4.1. Privacy Information for Facebook Components
Some of our websites use social plugins and components of the social network Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA.
For the processing of personal data of individuals living outside the USA or Canada, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible.
When you use Facebook plugins, your web browser establishes a direct connection to Facebook's servers.
The content of the plugin is transmitted directly to your browser by Facebook and integrated into the website.
We therefore have no influence over the extent of the data that Facebook collects using this plugin and therefore have no knowledge of the data collected by Facebook.
However, Facebook can learn through your use of the plugin that you have visited our website with your IP address, particularly if you are logged into your Facebook profile.
By clicking the Facebook “Like” button, you can also link content from our website to your Facebook profile, allowing Facebook to associate your visit to our website with your profile.
This also applies to the Facebook plugins that we use.
4.2. Privacy Information for YouTube Videos
Some of our websites contain embedded videos from the internet video platform YouTube.
These videos are provided by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
When you access a website containing a YouTube component or play an embedded video, your browser establishes a direct connection to YouTube's servers.
The content is transmitted directly to your browser by YouTube or downloaded and played.
We have no influence over the extent of the data collected by YouTube in this process and therefore have no knowledge of the data collected by YouTube.
However, YouTube may learn through your playback of the video that you have visited our website with your IP address, particularly if you are logged into your YouTube profile.
4.3. Privacy Information for Instagram Components
Some of our websites use plugins from the social network Instagram, such as the Instagram button.
These components are provided and operated by Instagram LLC, 1 Hacker Way, Building 14, First Floor, Menlo Park, CA, USA.
When you use Instagram plugins, such as the Instagram button, your web browser establishes a direct connection to Instagram's servers.
The content of the plugin is transmitted directly to your browser by Instagram and integrated into the website.
We therefore have no influence over the extent of the data collected by Instagram using this plugin and therefore have no knowledge of the data collected by Instagram.
However, Instagram may learn through your use of the plugin that you have visited our website with your IP address, particularly if you are logged into your Instagram profile.
By clicking the Instagram button, you can also link content from our website to your Instagram profile, allowing Instagram to associate your visit to our website with your profile.
4.4. Privacy Information for LinkedIn Plugins
Some of our websites use the LinkedIn plugin of the social network LinkedIn.
This component is provided and operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.
For data protection matters outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
When you use the LinkedIn button, your browser establishes a direct connection to LinkedIn's servers.
The plugin content is transmitted directly to your browser by LinkedIn and integrated into the website.
We therefore have no influence over the extent of the data collected by LinkedIn using this plugin and therefore have no knowledge of the data collected.
However, LinkedIn may learn through your use of the plugin that you have visited our website with your IP address, particularly if you are logged into your LinkedIn profile.
By clicking the LinkedIn button, you can also link content from our website to your LinkedIn profile, allowing LinkedIn to associate your visit to our website with your profile.
4.5. Privacy Information for Twitter Components
Some of our websites use plugins and components of the microblogging service Twitter.
These components are provided and operated by Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
When you use the Twitter button or Twitter components, your browser establishes a direct connection to Twitter's servers.
The content of the plugin or component is transmitted directly to your browser by Twitter and integrated into the website.
We therefore have no influence over the extent of the data collected by Twitter using these plugins and therefore have no knowledge of the data collected.
However, Twitter may learn through your use of the plugin that you have visited our website with your IP address, particularly if you are logged into your Twitter profile.
By clicking the Twitter button, you can also link content from our website to your Twitter profile or transmit data and information to Twitter or other Twitter users, allowing Twitter to associate your visit with your website visit.
4.6. Privacy Information for Xing Share Button
Some of our websites use the Share Button of the social network Xing.
This component is provided and operated by XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
When you use the Share Button, your browser establishes a direct connection to Xing's servers.
The content of the plugin or component is transmitted directly to your browser by Xing and integrated into the website.
We therefore have no influence over the extent of the data collected by Xing using this plugin and therefore have no knowledge of the data collected by Xing.
However, Xing may learn through your use of the plugin that you have visited our website with your IP address, particularly if you are logged into your Xing profile.
By clicking the Xing button, you can also link content from our website to your Xing profile or transmit data and information to Xing, allowing Xing to associate your visit with our website.
4.7. Privacy Information for Google Maps
Some of our websites use the mapping service Google Maps provided by Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin 4, D04 E5W5, Ireland.
Google Maps is a service used to display interactive maps.
We use the Google Maps API to visually display and integrate geographical information on individual websites, for example to show financial advisors located near you.
When you use Google Maps, data is also transmitted to Google and processed by Google, such as your IP address and other usage data.
This data may also be transferred to a Google LLC server in the USA.
Where legally required, we obtain your consent to use Google Maps pursuant to Article 6(1)(a) GDPR.
Otherwise, data processing is based on our legitimate interests pursuant to Article 6(1)(f) GDPR.
5. Communication via Messenger Services (WhatsApp, Signal, etc.)
Where applicable, you may also contact us via messenger services such as WhatsApp or Signal.
Information and instructions regarding communication via messenger services can be found in our Privacy Policy for Messenger Services.
6. Changes
We reserve the right to amend this Privacy Policy in the future.