PRIVACY + DATA PROTECTION POLICY
Last revised on July 27, 2020, effective as of August 12, 2018.
We hold the privacy of our subscribers and clients in the highest regard. Consequently, we have a strong privacy and data protection policy in place.
1. OVERVIEW OF DATA PROTECTION
The following gives an overview of what happens to your personal information when you visit our website.
1.2. DATA COLLECTION ON OUR WEBSITE
1.2.1. WHO IS RESPONSIBLE FOR THE DATA COLLECTION ON THIS WEBSITE?
The website operator processes the data collected on this website. The operator’s contact details can be found in the website’s required legal notice.
1.2.2. HOW DO WE COLLECT YOUR DATA?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form.
Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as details of your browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
1.2.3. WHAT FOR DO WE USE YOUR DATA?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.
1.2.4. WHAT RIGHTS DO YOU HAVE REGARDING YOUR DATA?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
1.2.5. ANALYTICS AND THIRD-PARTY TOOLS
You can object to this analysis. We will inform you below about how to exercise your options in this regard.
2. GENERAL INFORMATION AND MANDATORY INFORMATION
2.1. DATA PROTECTION
Please note that data transmitted via the internet (e.g., via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
2.2. NOTICE CONCERNING THE PARTY RESPONSIBLE FOR THIS WEBSITE
The party responsible for processing data on this website is:
444 Brickell Avenue, Suite 700
Miami, Florida 33131
Telephone: +1 (786) 600 1899
Email: [email protected]
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).
2.3. REVOCATION OF YOUR CONSENT TO THE PROCESSING OF YOUR DATA
Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
2.4. RIGHT TO FILE COMPLAINTS WITH REGULATORY AUTHORITIES
If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities.
2.5. RIGHT TO DATA PORTABILITY
You have the right to have data that we process based on your consent or in fulfillment of a contract automatically delivered to yourself or a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
2.6. INFORMATION, BLOCKING, DELETION
As permitted by law, you have the right to be provided at any time with information without any costs about any of your data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked, or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.
2.7. OPPOSITION TO PROMOTIONAL EMAILS
We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements concerning sending promotional and informational materials not explicitly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.
3. DATA COLLECTION ON OUR WEBSITE
Most of the cookies we use are so-called session cookies. They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
Cookies necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored according to Art. 6 paragraph 1, letter f of GDPR (General Data Protection Regulation). The website operator has a legitimate interest in storing cookies to ensure an optimized service is provided without technical errors.
3.2. CHANGE COOKIE PREFERENCES AND SETTINGS
3.3. SERVER LOG FILES
The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files.” These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the accessing computer
- Time of the server request
- IP address
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
4. ANALYTICS AND ADVERTISING
4.1. Google Analytics
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called “cookies.” These are text files stored on your computer, which allow an analysis of the website’s use by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize its website and its advertising.
4.1.1. IP anonymization
We have activated the IP anonymization feature on this website. Google will shorten your IP address within the European Union or other parties to the European Economic Area’s Agreement before transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of this website’s operator to evaluate your website’s use, compile reports on website activity, and provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
4.1.2. Browser plugin
You can prevent these cookies from being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
4.1.3. Objecting to the collection of data
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site:
4.1.4. Outsourced data processing
We have entered into an agreement with Google to outsource our data processing and fully implement the data protection authorities’ strict requirements when using Google Analytics.
4.1.5. Demographic data collection by Google Analytics
This website uses Google Analytics’ demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific person. You can disable this feature at any time by adjusting the ads settings in your Google account, or you can forbid the collection of your data by Google Analytics, as described in the section “Refusal of data collection.”
5.1. NEWSLETTER DATA
If you would like to receive our newsletter and/or premium market reports, we require a valid email address and information that allows us to verify that you are the owner of the specified email address and agree to receive this newsletter and/or premium market reports. No additional data is collected or is only collected voluntarily. We only use this data to send the requested information and not pass it on to third parties.
Therefore, we will process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) GDPR. You can revoke consent to the storage of your data and email address and their use for sending the newsletter at any time, e.g., through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.
When registering for the newsletter, the data will be used to distribute the newsletter until you cancel your subscription when said data are deleted. Data we have stored for other purposes (e.g., email addresses for the members’ area) remain unaffected.
This website uses the services of MailChimp to send newsletters. This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
MailChimp is a service that organizes and analyzes the distribution of newsletters. If you provide data (e.g., your email address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA.
MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.
We use MailChimp to analyze our newsletter campaigns. When you open an email sent by MailChimp, a file included in the email (called a web beacon) connects to MailChimp’s servers in the United States. This allows us to determine if a newsletter message has been opened and on which links you click. Also, technical information is collected (e.g., time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to tailor future newsletters to your interests better.
If you do not want your usage of the newsletter to be analyzed by MailChimp, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.
Data processing is based on Art. 6 (1) (a) GDPR. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.
When registering for the newsletter, the data will be used to distribute the newsletter until you cancel your subscription when said data are deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g., email addresses for the members’ area) remains unaffected.
5.3. COMPLETION OF A DATA PROCESSING AGREEMENT
We have entered into a data processing agreement with MailChimp, in which we require MailChimp to protect the data of our customers and not to disclose said data to third parties.