Privacy Policy
1. General notes and mandatory information
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.
1.1 Data processing controller
The data processing controller is:
SHS Gesellschaft für Beteiligungsmanagement mbH
Bismarckstraße 12
72072 Tuebingen
+49 7071 9169-0
datenschutz.shs@shs-capital.eu
1.2 Data protection officer
We have appointed a data protection officer for our company. If you have any questions that are not answered by this privacy statement, if you would like more detailed information or if you wish to exercise any of the rights to which you are entitled, please contact our data protection officer(s) using the following information:
+49 7071 9169-0
tuebingen@shs-capital.eu
1.3 SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme. You can recognise an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
2. Recording of data on this website
2.1 Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.
In some cases it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
We use cookies to make our website more convenient for you and to enable the use of certain features.
Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
2.2 Cookie consent with Borlabs Cookie
Our website uses cookie-consent technology by Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser and to document these in accordance with data protection regulations. This technology is provided by Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany (hereinafter referred to as “Borlabs”).
When you access our website, a Borlabs cookie is stored in your browser; this cookie stores the consent you have given, or the revocation of this consent. These data are not passed along to the provider of Borlabs Cookie.
The data collected will be stored until you ask us to delete it, until you delete the Borlabs Cookie yourself, or until the purpose for data storage no longer applies. This shall be without prejudice to any mandatory legal retention mandates. Details on the processing of data by Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/
Consent technology for Borlabs Cookie is used to obtain the legally required consent for the use of cookies. The basis in law for this is Art. 6 (1) Section 1 lit. c GDPR.
2.3 Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
These data are processed for the purpose of permitting use of the website (connection setup) as well as for system security, for technical administration, for the network infrastructure and to optimize the Internet offer.
These data are recorded on the basis of Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the technically flawless display and optimization of its website.
The access data collected in connection with use of our website will only be retained for as long as these data are required to achieve the purposes set forth above. For purposes of system security, your IP address will be stored on our web server for not more than 7 days.
2.4 Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfilment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular, statutory retention periods – remain unaffected.
3. Social media
3.1 LinkedIn plug-in
This website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.
Any time you access a page of this website that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.
The use of the LinkedIn plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.
4. Analysis tools and advertising
4.1 Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored.
The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
4.1.1 IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyse your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.
4.1.2 Browser plug-in
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
4.1.3 Objection to the recording of data
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
4.1.4 Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.
4.1.5 Demographic parameters provided by Google Analytics
This website uses the function “demographic parameters” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender and interests of website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.
4.1.6 Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en
4.2 HubSpot
We use HubSpot for our online marketing activities. This is an integrated software solution with which we cover different aspects of our online marketing. These include:
- Content management (website and blog)
- Email marketing (newsletters and automated mailings, e.g. to provide downloads)
- Social media publishing & reporting
- Reporting (e.g. traffic sources, access, etc. …)
- Contact management (e.g. user segmentation & CRM)
- Landing pages and contact forms
This information and the content of our website are stored on the servers of our software partner HubSpot. They can be used by us to contact visitors to our website and to determine which services of our company are of interest to them.
All information we collect is subject to this privacy policy. We use all the information we collect to optimize our marketing.
HubSpot is a software company from the USA with a branch in Ireland.
Contact:
HubSpot
2nd Floor 30 North Wall Quay
Dublin 1, Ireland
Telephone: +353 1 5187500
HubSpot is certified under the terms of the “EU – U.S. Privacy Shield Framework” and is subject to the TRUSTe’s Privacy Seal and the “U.S. – Swiss Safe Harbor” framework.
Click here for more information on HubSpot’s privacy policy.
Click here for more information from HubSpot regarding EU data protection regulations.
Click here & here for more information on the cookies used by HubSpot.
5. Newsletter
If you would like to subscribe to the newsletter offered on this website, we will require an e-mail address as well as your first and last name to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. You will then receive an e-mail from us, in which we request you to confirm your registration for our newsletter again (double opt-in). No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
6. Other plug-ins and tools
6.1 Google Web Fonts
This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. The Google Fonts are installed locally. No connection to Google servers is established in this process.
For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
7. Applications
7.1 Handling of applicant data
We offer you the opportunity to submit job applications (e.g. by e-mail or by post). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.
7.2 Scope and purpose of data collection
If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 New GDPR according to German Law (Negotiation of an Employment Relationship), Art. 6 Sect. 1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6 Sect. 1 lit. a GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.
If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 New GDPR and Art. 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing system.
7.3 Data archiving period
If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.
Longer storage may also take place if you have given your agreement (Article 6 (1) (a) GDPR) or if statutory data retention requirements preclude the deletion.
7.4 Admission to the applicant pool
If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.
Admission to the applicant pool is based exclusively on your express agreement (Art. 6 para. 1 lit. a GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke their consent at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.
8. Information on the rights of data subjects
If your personal data are processed, then you are a data subject within the language of GDPR, and you have the following rights vis-à-vis the controller:
8.1 Right to information
According to Art. 15 GDPR, you have a right to information. Specifically, this means you have the right to request confirmation from the data controller as to whether we process personal data pertaining to you. If this is the case, you also have the right to obtain information about these personal data, and about the information set forth in Art. 15 (1) GDPR. This includes, for instance, information about the purposes for processing, about the categories of personal data processed, and about the recipients or categories of recipients to whom the personal data have been or will be disclosed (Art. 15 (1) lit. a), b) and c) GDPR).
8.2 Right of rectification
According to Art. 16 GDPR, you have a right to rectification. What this means specifically is that you have the right to request immediate rectification of incorrect personal data about you as well as completion of incomplete personal data.
8.3 Right of erasure (“right to be forgotten”)
Art. 17 GDPR grants you a right to erasure of data about you (also known as the “right to be forgotten”). In other words, you have the right to request that we erase personal data relating to you immediately, and we have an obligation to erase personal data at once if one of the reasons set forth in Art. 17 (1) GDPR applies. This may be the case, for example, if personal data are no longer needed to fulfil the purposes for which they were collected or were otherwise processed (Art. 17 (1) lit. a) GDPR).
If we have made the personal data public and are obliged to erase them, we are also under an obligation, taking account of available technology and the cost of implementation, to take reasonable steps, including technical ones, to inform other controllers responsible for processing these personal data that a data subject has requested that they erase all links to these personal data, together with any copies or replications thereof (Art. 17 (2) GDPR).
By way of exception, the right to erasure (“right to be forgotten”) does not apply if processing of the data in question is required for the reasons set forth in Art. 17 (3) GDPR. This may be the case, for example, insofar as processing is required to meet a legal obligation, or to establish, exercise or defend legal claims (Art. 17 (3) lit. a) and e) GDPR).
8.4 Right to demand processing restrictions
Under certain conditions, Art. 18 GDPR also guarantees your right to restriction of processing of these data. This means that you have the right to request that we restrict processing if one of the conditions listed in Art. 18 (1) GDPR is met. This may be the case, for example, if you dispute the accuracy of personal data about you. In this case, processing is restricted for a period sufficient to permit us to review the personal data for accuracy (Art. 18 (1) lit. a) GDPR). Restriction involves the marking of stored personal data with the goal of restricting their future processing (Art. 4 No. 3 GDPR).
8.5 Right to data portability
As a data subject, you also have a right to data portability in accordance with Art. 20 GDPR. This means that you generally have the right to receive the personal data about you that you have provided to us, presented in a structured, commonly used and machine-readable format, and that you have the right to transmit these data to another data controller unimpeded by us, provided that the processing is based on consent issued pursuant to Art. 6 (1) lit. a) or Art. 9 (2) lit. a) GDPR, or on a contract pursuant to Art. 6 (1) lit. b) GDPR, and provided that such processing is carried out with the aid of automated procedures (Art. 20 (1) GDPR).
In exercising your right to data portability, you always have the right to take steps to see to it that your personal data are transmitted directly by us to another data controller, provided that this is technically feasible (Art. 20 (2) GDPR).
8.6 Right to object
Art. 21 GDPR guarantees your right to object. We expressly inform you, as a data subject, of your right to object not later than upon our first communication with you.
Please find more detailed information below:
8.6.1. Right to object on grounds resulting from the situation specific to the data subject
As a data subject, you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you on the basis of Art. 6 (1) lit e) or f) GDPR, including profiling based on those provisions.
In the case of an objection for reasons stemming from your particular situation, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing and these grounds override your interests, rights and freedoms, or the processing is in service of establishment, exercise or defence of legal claims.
8.6.2. The right to object to direct marketing
If personal data is processed to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising.
In the event that you object to processing for direct marketing purposes, we will no longer process the personal data concerned for these purposes
8.7 Right to revoke consent
If the processing is based on consent pursuant to Art. 6 (1) lit. a) or Art. 9 (2) lit. a) GDPR, you as a data subject have the right to revoke your consent at any time pursuant to Art. 7 (3) GDPR. Revocation of consent will not affect the legality of processing undertaken on the basis of this consent prior to its revocation. We will bring this to your attention before you grant your consent.
8.8 Right to lodge a complaint with a supervisory authority
As a data subject, you have the right to lodge a complaint with a supervisory authority subject to the conditions as set forth in Art. 77 GDPR.
The supervisory authority responsible for us is the State Officer for Data Protection and Freedom of Information of the German state of Baden-Württemberg.
You can find contact data here: https://www.baden-wuerttemberg.datenschutz.de/kontakt/
As of 12/2020