PRIVACY POLICY

INFORMATION FOR INTERESTED PARTIES (WEBSITE)

regarding the processing of personal data according to Art. 13 General Data Protection Regulation

Date: 09 January 2023

RESPONSIBLE PERSON

Responsible for the processing of personal data are:

TWS Partners AG, Gollierstr. 4, 80339 Munich, Germany, Tel: +49 (0) 89 / 2000 40 0 | info@tws-partners.com

TWS Partners Limited, Barclays Bank Chambers, Bridge Street, Stratford-Upon-Avon CV37 6AH, England Tel: +49 (0) 89 / 2000 40 0 | info@tws-partners.com

(in the following stated as TWS Partners)

Represented by Marcus Schreiber, Dr. Andreas Engel, Dr. Alexander Klein, Dr. Sebastian Moritz

DATA PROTECTION OFFICER

You can reach our data protection officer at:

Maren Leschke, datenschutz@tws-partners.com

PRIVACY STATEMENT

To us, protection and security of your data and your privacy are a top priority. We only collect personal information to a limited extent and, where necessary, for:

  • Providing our services
  • Contract performance (including initiation, conclusion, fulfilment and termination of a contract)
  • Processing and answering of inquiries (contact form and download form),
  • Secure operation,
  • Improvement of our offers,
  • Prevention, detection and investigationof potentially prohibited or illegal activities

We treat your personal data confidential and according to the relevant data protection regulations as well as this privacy policy. Using our website is normally possible without providing personal data. Collecting personal data (e. g. name, e-mail-address, address) only happens on a voluntary basis. This data will be used by TWS Partners AG, TWS Partners Limited and TWS Digital Products GmbH (nnamu). It will not be transmitted to further third parties without consent. To ensure that you are fully aware of the processing of personal data on our websites, we took the trouble to compile this information comprehensively and comprehensibly. We assure to make all necessary technical and organizational efforts to protect your data. We would like to make you aware that online data transmission (e. g. communication via e-mail) can exhibit security gaps. A complete protection of data from access through third parties is not possible.

LEGAL NOTE

All information on our website was carefully researched and checked. We endeavour to constantly expand and update this information offer. However, we cannot guarantee for the completeness, accuracy and timeliness. Furthermore, we reserve the right to make changes or additions to the information provided. We assume no liability for claims in connection with these websites. Prior to linking to external sites, TWS Partners will conduct a thorough content review and reasonable review of the privacy practices of the external sites. Only when there was no reference to unlawful or infringing content, such pages are referred to by means of a link. A liability for the content of external sites referred to by link is not assumed by TWS Partners. For the content and the legal conformity of the linked sites their operators are and remain exclusively responsible. Upon notice, links to impermissible content are removed immediately. All rights reserved. Content and structure as well as texts, pictures, graphics, files etc. used on the website are subject to copyright and other laws for the protection of intellectual property. Their dissemination, modification, commercial use or use in other websites or media is not permitted or requires our prior consent.

PURPOSES OF PROCESSING AND LEGAL BASIS

Personal data is processed for the provision of our website. For detection and defence against attacks we store the IP addresses.

We consider visiting our website as performance of the contract. The legal basis of processing is Art. 6 Par.1 letter b and f General Data Protection Regulation.

TYPES OF DATA AND AFFECTED PEOPLE

This personal data of visitors of this website (affected people) is processed:

  • IP-address
  • Time
  • Browser-Type/-Version*
  • Operating System*
  • Referrer URL (the previously visited page)*
  • Cookies

COOKIES

This website partly uses cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly. Cookies are small text files that are stored on your computer and saved by your browser. They allow us to recognize your browser during your next visit. You can adjust your browser to the setting that you are informed about the setting of cookies and only allow cookies in individual cases, the acceptance of cookies for certain cases or generally exclude and activate the automatic deletion of cookies when closing the browser. Deactivating cookies may limit the functionality of this website.

SERVER-LOG-FILES

Server-side log files are only stored in an anonymous form.

DOUBLE OPT IN

In addition, those who download content through Double Opt-in (constituting a further group of affected people) voluntarily disclose their name, company and email address information. Interested parties actively agree to the storage of this data via e-mail.

*If necessary, you can suppress this data by making appropriate settings on your system. Likewise, these data are separated from the IP address immediately after collection and processed only for statistical purposes. From then, an assignment of this data to a natural person is no longer possible.

PROCESSING DUE TO A JUSTIFIED INTEREST

The processing for detection and defence against attacks is a justified interest (compare Recital 49 General Data Protection Regulation).

RECIPIENT

When opening a website, servers used for site transport receive at least sender and recipient information. Content (=our website) is transmitted when not encrypted.

THIRD COUNTRY

Opening a website cannot guarantee that the data will remain within the EU. Where applicable, it might be technically possible, due to the operating principles of the Internet, that a request while being in transit to us or vice versa, is redirected via a server in an insecure third country. This cannot be prevented either.

DURATION OF DATA RETENTION

We store IP addresses of a website visit for 7 days.

RIGHT TO ACCESS, CORRECTION, DELETION, RESTRICTION, DATA PORTABILITY

As we separate your IP address from the rest of the data immediately after visiting the website, we cannot provide you with any meaningful information about this:

You can find out your IP address in the settings of your device. Wee would need this to provide you with information. The information would consist of your IP address that you already know. Moreover, we are not obliged to provide such information under Art. 12 Par.Par. 2 and Art 11 of the General Data Protection Regulation.

Likewise, correction, deletion, restriction and data portability are not applicable here.

GOOGLE ANALYTICS

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

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.

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.

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: tools.google.com/dlpage/gaoptout.

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.

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.

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.”

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.

RIGHT TO APPEAL

If you are dissatisfied, please let us know using the above contact details. Please use these equally if you notice a privacy violation. Thank you! For any problems with data processing, you can contact our data protection officer at any time (contact details see above).

In principal,you have the right to complain at a supervisory authority about the processing of your data. This can be done at a regulatory authority responsible for your place of residence or the regulatory authority responsible for us.

The regulatory authority responsible TWS Partners AG: Bayerisches Landesamt für Datenschutzaufsicht Postfach 606 91511 Ansbach Germany Tel: +49 (0) 981 53 1300 Email: poststelle@lda.bayern.de Internet: https://www.lda.bayern.de

The regulatory authority resonsible TWS Partners Limited: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF England Te: +44 1625 545 700 EMail: n/a Internet: https://ico.org.uk/

PROVISION OF YOUR DATA

You initiate every website request, so you provide us with the above-mentioned data. Your IP address is required, otherwise we cannot display our website

AUTOMATED DECISION

There is no automated decision.