Data Protection
Privacy Policy of UNIVERS Capital GmbH
§ 1 General information on the structure of our website and the privacy policy
The following general information provides information about the structure of the website and the organization of its operators. It applies regardless of where you are on our website and which functions you use. To explain as clearly as possible where we process which of your personal data, you will find three additional subpages linked above this text. There you will find information about the respective data processing when you visit our website, after registering with UNIVERS Capital, and information on how your data is handled as part of an application process. The website "universcapital.de" and its subpages are jointly operated by "UNIVERS Capital GmbH" and its subsidiary "UNIVERS Capital GmbH." UNIVERS Capital GmbH provides the website, while UNIVERS Capital GmbH ensures the functionality of the product offered. As soon as the page visit goes beyond a mere view and interaction with the visitor takes place, for example, when the visitor clicks the "Register" or "Investment Cockpit" fields, the visitor leaves the overview page of "UNIVERS Capital GmbH" and enters the area of responsibility of "UNIVERS Capital GmbH." The type, amount, and purpose of the processing of personal data, as well as the identity of the controller, may vary depending on which part of the website you are on.
Both operators of these websites take the protection of your personal data very seriously. It will be treated confidentially and in accordance with the applicable statutory data protection regulations and this privacy policy.
§ 2 Data Protection on Our Website
When you access this website, various personal data is processed. Personal data is information that can be used to identify you personally. This privacy policy explains which data we collect and what we use it for. It also explains how and for what purpose this happens. If we have received personal data from you via other means (e.g., by email), the following privacy policy also applies. We would like to point out that data transmission over the Internet (e.g., when communicating via email) can be subject to security gaps. Complete protection of data from access by third parties is not possible.
If you have any questions about this privacy policy or the processing of your personal data, please contact the following responsible party:
Notice regarding the responsible party
UNIVERS Capital GmbH
Grolmanstraße 36, 10623 Berlin, Germany
Phone: +49 (0) 30 - 810 56 61 18
Email: datenschutz@universcapital.de
- hereinafter also referred to as "UNIVERS Capital GmbH"
Data processing on this website is carried out by the website operator. As the provider of this website, we are, on the one hand, the controller within the meaning of Art. 4 (7) GDPR, and, on the other hand, the service provider within the meaning of Section 2 No. 1 TTDSG.
Basis for data processing
Your personal data will be processed exclusively i) on the basis of your consent, ii) to fulfill a contractual relationship, iii) based on the legitimate interest of the controller in data processing, or iv) to fulfill a legal obligation or in the public interest.
Revocation of your consent to data processing
If data processing is based on your express consent, this consent can be revoked at any time without giving reasons and with effect for the future. An informal email notification to us is sufficient. The legality of the data processing carried out up to the time of revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)
If the data processing is based on the legitimate interest of the controller in data processing or on tasks in the public interest that have been assigned to the controller (Art. 6 (1) (e) or (f) GDPR), you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation. This also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims (objection pursuant to Art. 21 (1) GDPR).
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection pursuant to Art. 21 (2) GDPR).
Rights of the Data Subject
Due to statutory data protection regulations, you have extensive rights regarding your data. You can exercise these rights by sending an email to datenschutz@universcapital.de. These include, in particular:
Right to information
Upon request, Univers Capital will provide you with comprehensive information about all data stored about you at UNIVERS Capital within the legally stipulated period. This information includes the personal data, the purpose of the processing, and the type of processing.
Right to rectification
You have the right to have your personal data corrected, supplemented, or amended at any time. UNIVERS Capital may require proof of your identity before UNIVERS Capital can fulfill this right.
Right to data portability
You have the right, where technically feasible, to have all data stored about you at UNIVERS Capital transferred to another company.
Right to erasure
At your request, UNIVERS Capital will delete all personal data concerning you stored by UNIVERS Capital within the legally stipulated period. If there is a statutory retention obligation, the data will only be deleted after this period has expired. This data will be blocked internally for further use.
Right to Restriction of Processing
You have the right to request that the processing of your personal data be restricted. The right to restrict processing applies in the following cases:
(1) If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request that the processing of your personal data be restricted.
(2) If the processing of your personal data was/is unlawful, you can request that the processing be restricted instead of deleted.
(3) If we no longer need your personal data, but you require it to exercise, defend, or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of deleted.
(4) If you have lodged an objection pursuant to Art. 21 (1) GDPR, your interests must be weighed against ours. As long as it is not yet clear whose interests prevail, you have the right to request that the processing of your personal data be restricted.
If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims or to protect the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, those affected have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged violation. This right of complaint exists without prejudice to other administrative or judicial remedies.
Data Security
SSL or TLS Encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the browser's address bar changing from "http://" to "https://" and by the lock symbol in your browser bar.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Encrypted Payment Transactions on This Website
If, after concluding a paid contract, you are required to provide us with your payment details (e.g., account number for direct debit authorization), this data is required for payment processing.
Payment transactions using common payment methods (direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the browser's address bar changing from "http://" to "https://" and by the lock symbol in your browser's address bar.
With encrypted communication, your payment data that you send to us cannot be read by third parties.
§ 3 Recording of Telephone Conversations
Telephone conversations between UNIVERS Capital and clients in connection with securities products must be recorded in accordance with the requirements of the MiFID II Code of Conduct. This obligation to record and retain recordings arises from Section 83 (3) of the German Securities Trading Act (WpHG), which specifies the Delegated Regulation (EU) 2017/565 (DV) and the minimum requirements for risk management established by BaFIN (MaRisk BTO 2.2.1 (Section 4)). Thus, data processing is carried out to fulfill legal obligations, Art. 6 (1c) GDPR.
The information regarding the responsible body and the rights of data subjects under Section 2 applies accordingly.
When recording voice calls, we process not only the actual conversation content but also technical information from the telephone system, which was either generated there or provided by the telephone company. This includes the telephone numbers involved in the call, the start time of the call, and the duration of the call.
Recordings must always be expected, even without notice, if the conversation takes place in the trading area of UNIVERS Capital.
Within UNIVERS Capital, those departments that need your data to fulfill the processing purpose or legal requirements will have access to it. Employees, responsible supervisory authorities, and auditors may access the recorded data to fulfill legal requirements. In the event of legal disputes, we will hand over the recordings to lawyers and courts if we are legally compelled to do so or have our own legal positions to represent. When operating our telephone systems, we involve service providers who work strictly according to our specifications and must meet a statutory level of data protection (so-called data processors). These service providers do not process your data for purposes other than those specified by us.
The data is generally stored for five or seven years according to Section 83 (8) of the German Securities Trading Act (WpHG). Should special circumstances arise that justify a legitimate interest on the part of UNIVERS Capital in retaining the recordings for a longer period, this will be for a maximum of ten years and two weeks. After this period, the data will be automatically deleted.
§ 4 Data Protection Officer
Legally Required Data Protection Officer
We have appointed an external data protection officer for UNIVERS Capital GmbH. You can reach him/her at:
UNIVERS Capital GmbH
Data Protection Officer
Grolmanstraße 36, 10623 Berlin, Germany
Telephone: +49 (0) 30 - 810 56 61 18
Email: datenschutz@universcapital.de
§ 5 Storage
Your data will be stored for as long as necessary to provide the services. Should longer storage be required due to legal regulations, it will be stored until the expiration of this period.
§ 6 Copyright
The content of our website, in particular the products presented and the data provided, is protected by copyright. The content may not be reproduced and/or published, in whole or in part, or stored in an information system without prior written permission. The display of this website in third-party frames is only permitted with express written consent.
§ 7 Scope of the Privacy Policy
This Privacy Policy applies exclusively to the joint UNIVERS Capital website.
This Privacy Policy does not apply to services offered by other companies or individuals, including products or websites displayed to you in search results, websites that may contain services from UNIVERS Capital GmbH, or other websites linked to UNIVERS Capital GmbH services. This privacy policy does not cover the handling of information by other companies or organizations that advertise services and may use cookies, pixel tags, and other technologies to provide and deliver relevant ads.
§ 8 Analysis Tools and Advertising
If cookies are used on our website for analysis or advertising purposes, we will inform you about this via Usercentrics' cookie consent technology. If the cookies used are not classified as essential, you have the option of giving or withdrawing your consent.
Further information about the cookies currently used and your consent can be obtained via the fingerprint in the lower left corner of our homepage.
§ 9 Changes
Updating the content of this privacy policy may be necessary, among other things, due to organizational, legal, or regulatory changes. The most current privacy policy will be published on this website.
§ 10 Newsletter
Newsletter Data
You can subscribe to the newsletter at any time, regardless of whether you are registered or not. If you wish to receive the newsletter, we will require an email address from you again, as well as information that allows us to verify that you are the owner of the provided email address and that you agree to receive the newsletter, as this is a process independent of registration. Further data is not collected or is only collected on a voluntary basis. We use this data exclusively to send the requested information and do not share it with third parties.
The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke your consent to the storage of your data, your email address, and their use for sending the newsletter at any time by sending an email to datenschutz@universcapital.de or via the "Unsubscribe" link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after you unsubscribe. Data stored by us for other purposes remains unaffected.
Shipping service provider
The newsletter is sent via the shipping service provider Braze [https://www.braze.com/]. You can view the shipping service provider's privacy policy here: https://www.braze.com/company/legal/privacy/
The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 (1) (f) GDPR and a data processing agreement pursuant to Art. 28 (3) (1) GDPR. The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 (1) (f) GDPR and a data processing agreement pursuant to Art. 28 (3) (1) GDPR. Should personal data be transferred to the USA, the shipping service provider must comply with the provisions of the standard contractual clauses pursuant to Art. 46 GDPR.
The shipping service provider will use the transmitted personal data exclusively on the instructions of UNIVERS Capital and on the basis of the data processing agreement. Furthermore, the shipping service provider is entitled to use the transmitted recipient data in pseudonymous form, i.e., without assignment to a user, to optimize or improve its own services, e.g., for the technical optimization of the delivery and presentation of the newsletter or for statistical purposes.
Performance Measurement (iGoDigital)
The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. During this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. Statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider, to monitor individual users. The evaluations serve us much more to identify the reading habits of our users and to adapt our content to them or to send different content based on the interests of our users.
Unfortunately, a separate revocation of the success measurement is not possible; in this case, the entire newsletter subscription must be canceled. For this purpose, the iGoDigital cookie is also used on our website.
§ 11 Plugins and Tools
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called website tags via a single interface (and thus integrate, for example, Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal user data. Regarding the processing of users' personal data, please refer to the following information on Google services. Terms of Use: https://www.google.com/intl/de/tagmanager/use-policy.html
Google Web Fonts
This website uses so-called web fonts provided by Google for the uniform display of fonts. When you visit a page, your browser loads the required web fonts into your browser cache to display text and fonts correctly.
For this purpose, the browser you use must establish a connection to Google's servers. This allows Google to know that our website was accessed via your IP address. Google Web Fonts are used to ensure a consistent, appealing, and, above all, understandable presentation of our online offerings. Ensuring the comprehensibility and consistent, device-independent readability of our offerings is necessary for a valid contract conclusion and therefore required within the meaning of Art. 6 (1) (b) GDPR.
If your browser does not support web fonts, a standard font from your computer will be used.
Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=de
Zenloop
To optimize our website and our products, we ask you to rate us. We use the so-called Net Promoter Score (NPS).
This serves to safeguard our legitimate interests in the optimal marketing of our offerings in accordance with Art. 6 (1) (f) GDPR, based on a balancing of interests. The NPS and the services advertised with it are offered by zenloop GmbH, Brunnenstraße 196, 10119 Berlin.
When you submit a review, the web server automatically saves a so-called server log file, which contains, for example, your IP address, the date and time of the review, the amount of data transferred, and the requesting provider (access data), and documents the review. This access data is not evaluated and is automatically overwritten no later than seven days after your visit to the site.
Salesforce
We use the CRM system of the provider salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 Munich, to process user inquiries more quickly and efficiently (legitimate interest pursuant to Art. 6 (1) (f) GDPR).
Salesforce uses user data only for the technical processing of inquiries and does not share it with third parties. To use Salesforce, at least a correct email address is required. Pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect additional data (name, address).
If users do not agree to data collection via and storage in Salesforce's external system, we offer them alternative contact options for submitting service requests via email, telephone, fax, or mail.
Users can find further information in Salesforce's privacy policy: https://www.salesforce.com/de/company/privacy/
§ 12 Other Service Providers
Trustpilot A/S
UNIVERS Capital GmbH may contact platform users by email and invite them to rate our service and/or products so that we can further optimize them (the "Purpose"). Since we work with an external company, Trustpilot A/S ("Trustpilot"), to collect customer feedback, we will share the user's name, email address, and reference number with Trustpilot for this purpose. Users who would like to learn more about how Trustpilot processes their data can view the company's privacy policy here. UNIVERS Capital GmbH may also use such ratings in other advertising and materials for promotional and promotional purposes.
§ 13 Data Processing When Visiting Our Website
As soon as you click on our website, your personal data will be processed by us via cookies. Initially, only your IP address will be processed to the extent necessary for the operation of our website. When you visit the website for the first time, a cookie banner opens in accordance with the provisions of Section 25 of the German Telemedia Act (TTDSG), which offers you the option of selecting the scope of further processing by selecting specific cookie types. You can subsequently change this selection at any time within the cookie settings.
Responsibility
The processing of cookies during your website visit is the responsibility of UNIVERS Capital GmbH.
Cookies
Some websites use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies are used to make our service more user-friendly, effective, and secure. Cookies are small text files that are stored on your computer and saved by your browser.
There are three categories of cookies:
- Essential cookies to ensure basic website functions.
- Functional cookies to ensure website performance.
- Marketing cookies to display ads relevant to your interests.
Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser the next time you visit. Only device and browser data are saved for this purpose.
You can set your browser to inform you about the use of cookies and to only allow cookies in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
Cookie Consent with Usercentrics
This website uses the cookie consent technology from Usercentrics to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document this consent in compliance with data protection regulations. The provider of this technology is Usercentrics GmbH, Rosental 4, 80331 Munich, website: https://usercentrics.com/de/ (hereinafter "Usercentrics").
When you visit our website, the following personal data is transferred to Usercentrics:
-Your consent(s) or the revocation of your consent(s)
-Your IP address
-Information about your browser
-Information about your device
-Time of your visit to the website
Furthermore, Usercentrics stores a cookie in your browser to be able to assign the consent granted or its revocation to you. The data collected in this way is stored until you request deletion, delete the Usercentrics cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected.
Server log files
The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:
- Browser type and version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
New Relic – Server Monitoring and Error Tracking
With the help of server monitoring and error tracking, we ensure the availability and integrity of our online offering and use the data processed in the process to technically optimize our online offering.
For these purposes, we use the service New Relic, Inc. Attn: Legal Department, 188 Spear Street, Suite 1200, San Francisco, CA 94105, USA. New Relic processes aggregated performance data, i.e., performance, utilization, and comparable technical values, which provide information about the stability and any anomalies of our online offering. In the event of errors or abnormalities, individual inquiries from users of our online service are recorded pseudonymously in order to identify and resolve problem sources. In this case, pseudonym means, in particular, that the users' IP addresses are stored with the last two digits abbreviated (so-called IP masking). The aggregated data is deleted after three months, and the pseudonymized data after seven days.
Further information on the processing of personal data by New Relic can be found in the service's privacy policy: https://newrelic.com/termsandconditions/privacy
Contact form / chat tool
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not share this data without your consent.
The data you enter in the contact form will remain with us until you request its deletion, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
Inquiries by email, telephone, or fax
If you contact us by email, telephone, or fax, your inquiry, including all personal data resulting from it (name, inquiry), will be stored and processed by us for the purpose of processing your request. We will not disclose this data without your consent.
The data you send to us via contact inquiries will remain with us until you request its deletion, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.
§ 14 Purposes and Legal Basis of Processing
Cookies that are necessary to carry out electronic communication or to provide certain functions you request (e.g., shopping cart function) are stored on the basis of UNIVERS Capital's legitimate interest (Art. 6 (1) (f) GDPR). The website operator has a legitimate interest in storing cookies to ensure the technically error-free and optimized provision of its services. If other cookies (e.g., cookies for analyzing your surfing behavior) are stored, these are treated separately in this privacy policy.
Usercentrics
Usercentrics is used to obtain the legally required consent for the use of certain technologies. The legal basis for this is Art. 6 (1) (c) GDPR.
Server Log Files
Server log data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be recorded.
New Relic
We use New Relic based on our legitimate interests in the security, accuracy, and optimization of our online offering in accordance with Art. 6 (1) (f) GDPR.
Contact form / chat tool
The data entered into the contact form is therefore processed exclusively on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke this consent at any time. An informal email to us is sufficient. The legality of the data processing operations carried out up to the time of revocation remains unaffected by the revocation.
Inquiry by email, telephone, or fax
The processing of relevant data in the context of your inquiries is based on Art. 6 (1) (b) GDPR, provided that your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6 (1) (a) GDPR) and/or on our legitimate interests (Art. 6 (1) (f) GDPR), as we have a legitimate interest in the effective processing of the enquiries addressed to us.
§ 15 Data processing after registration at "universcapital.de"
You can register on our website to use additional features on the site. We will use the data you enter only for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full; otherwise, we will reject your registration. As a provider of financial services, we are obligated, among other things, to ensure the identity of our users to prevent money laundering. This mandatory information includes, in addition to personal master data, the bank details necessary for processing the contract. The identity verification itself is carried out by a service provider, which only transmits confirmation or non-confirmation of your identity to us, but no data from the legitimation process.
If you would like to register with UNIVERS Capital, you initially only need your email address.
As soon as you wish to actively use our services, the following personal data will be requested:
-First name/Last name
-Title (optional)
-Gender
-Nationality
-Mobile phone number (optional)
-Email address
-Telephone number (optional)
-Address (optional)
-Date/place of birth (optional)
-Identification data (ID details: number, authority, validity, etc.)
-Tax residency
-Tax ID (optional)
-Voluntary additional information (marital status, occupation, award system data)
The data entered during registration is processed based on your consent (Art. 6 (1) (a) GDPR). You can revoke your consent at any time. An informal email to us is sufficient. The legality of any data processing already carried out remains unaffected by the revocation.
The data collected during registration will be stored by us for as long as you are registered on our website and will then be deleted. Statutory retention periods remain unaffected.
Responsibility
The processing of personal data during your registration and use of our services is the responsibility of "UNIVERS Capital GmbH."
Processing of data (customer and contract data)
We collect, process, and use personal data only to the extent necessary to establish, define, or modify the legal relationship (master data). This is done on the basis of Art. 6 (1) (b) GDPR, which permits the processing of data to fulfill a contract or for pre-contractual measures. We collect, process, and use personal data regarding the use of our websites (usage data) only to the extent necessary to enable or bill the user for the use of the service.
The customer data collected will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.
Data transfer upon conclusion of a contract for services and digital content
We only transfer personal data to third parties if this is necessary for the purpose of contract processing, for example, to the service provider commissioned with identification or payment processing.
Further transmission of data will not occur, or only if you have expressly consented to the transmission or if this is necessary within the scope of our legitimate interest. Your data will not be passed on to third parties without your express consent, for example for advertising purposes. The basis for data processing is Art. 6 (1) (b) GDPR, which permits the processing of data for the fulfillment of a contract or for pre-contractual measures.
§ 16 Purposes and Legal Basis of Processing
You have registered with us
During the registration process, your login data, such as your email address, will necessarily be processed by us.
The purpose of data processing at this stage is to expand our community and initiate business between "UNIVERS Capital GmbH" and you. We consider your registration with us on the portal as the first step towards initiating business and contracts. Therefore, the legal basis for data processing is the fulfillment of the contract (Art. 6 (1) (b) GDPR). You can revoke your consent to receive emails from us at any time. We will then not send you any further emails. We store your data as long as the respective legal basis exists. If you have not made an investment with us, we will delete your data immediately upon your request.
Otherwise, we will delete your account after three months if we determine that you have not logged in during this period.
We will not forward your data to a third country outside the EU or EEA. Furthermore, your data will not be passed on to any third parties. It will remain within "UNIVERS Capital GmbH" and its parent company "UNIVERS Capital."
You have registered and identified yourself.
If, in addition to registering with us on the platform, you have also identified yourself, this is an indication to us that you wish to make an investment with us. The purpose of the processing is the initiation or execution of a contract. The legal basis in this case would be the initiation of a contract within the meaning of Art. 6 (1) (b) GDPR. At the moment you opened a securities account through us, you also concluded a securities account management agreement with the respective financial institution, "MANGOPAY S.A." or "Tangany GmbH." In this case, the legal basis is also Art. 6 (1) (b) GDPR.
In addition, we are obligated under the Money Laundering Act (GwG) to verify your identity when opening a securities account. In doing so, we are subject to a legal obligation pursuant to Art. 6 (1) (c) GDPR.
If you would also like to open a securities account, we will forward your data to the custodian bank so that we can book your bonds. The purpose of forwarding your data is to fulfill the contract by opening a securities account with our partner institutions. As long as you have not yet invested, we will delete your data after a certain period of inactivity on this platform, but no earlier than seven years. The German Money Laundering Act (GwG) stipulates a retention period of seven years for identification data after opening an account or securities account.
Your data will not be transferred to a third country outside the EU or the EEA.
You have already invested.
The purpose of processing in this case is the execution or settlement of an existing contract. It is necessary for us to know to whom we should make the interest payments.
In this case, your data will be processed on the legal basis of contract execution and settlement in accordance with Art. 6 (1) (b) GDPR. Furthermore, your data will be processed due to a legal obligation in accordance with Art. 6 (1) (c) GDPR. The following are relevant here: the German Money Laundering Act (GwG); German Banking Act (KWG) and German Investment Supervision Act (KAG). As long as your investment is active, we cannot and may not delete your data. Deleting personal data also constitutes processing within the meaning of Art. 4 No. 2 GDPR and requires a legal basis. However, due to the aforementioned laws and the German Fiscal Code (AO), we are subject to statutory retention periods, which prohibit us from deleting certain data for a period of time specified by law. These retention periods also apply after your investment with us has ended. Deletion of the data is only possible once the retention periods have expired. The retention periods are a maximum of ten years after the end of your investment.
§ 17 Data processing during the application process
We process applicant data only for the purpose and within the scope of the application process, in accordance with legal requirements. The application process is generally conducted via our partner "Personio." The application process requires applicants to provide us with their application data. The required applicant data is marked, if we offer an online form, and primarily concerns personal master data. Otherwise, it is derived from the respective job descriptions. This generally includes personal information (personal master data), postal and contact addresses, as well as the documents required for the application, such as cover letters, resumes, and the information from the attached certificates and supporting documents. Applicants can also voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the manner and scope set out in this privacy policy.
If provided, applicants can submit their applications using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also submit their applications via email. Please note, however, that emails are generally not encrypted and applicants must ensure their own encryption. We therefore cannot assume any responsibility for the transmission path of the application between the sender and its receipt on our server and therefore recommend using an online form or sending it by mail.
Subject to a legitimate revocation by the applicant, applications will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and fulfill our documentation obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
§ 18 Purposes and Legal Basis of Processing
Should applicant data be processed by UNIVERS Capital or UNIVERS Capital GmbH via other channels than our careers page operated by "Personio," this processing of applicant data will be carried out to fulfill our (pre-)contractual obligations within the scope of the application process within the meaning of Art. 6 (1) (b) GDPR and Art. 6 (1) (f) GDPR, provided that data processing becomes necessary for us, e.g., in the context of legal proceedings (in Germany, Section 26 of the Federal Data Protection Act (BDSG) also applies). Furthermore, your data will be processed based on your consent, provided you have permitted us to keep your application on file.
If special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily disclosed during the application process, they will also be processed in accordance with Art. 9 (2) (b) GDPR (e.g., health data, such as severe disability status or ethnic origin).
If special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants as part of the application process, this data will also be processed in accordance with Art. 9 (2) (a) GDPR (e.g., health data if required for professional performance).
The data provided by applicants may be further processed by us for the purposes of the employment relationship if their application is successful. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. The same data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.