Privacy Policy

Responsible office
MainSky Asset Management AG
Reuterweg 49, 60323 Frankfurt am Main
Tel: 069-15049680-0, Fax: 069-15049680-29
www.mainsky.de
info@mainsky.de

Data Protection Coordinator
A data protection officer was not appointed because the legal requirements for this are not fulfilled. Every person concerned can contact us directly at any time with all questions and suggestions regarding data protection.

Data protection coordinator
MainSky Asset Management AG
Reuterweg 49, 60323 Frankfurt am Main
Tel: 069-15049680-0
datenschutz@mainsky.de

Responsible supervisory authority regarding data protection.
The supervisory authority responsible for our company in data protection matters is

The Hessian Commissioner for Data Protection and Freedom of Information
Postfach 3163, 65021 Wiesbaden
Gustav-Stresemann-Ring 1, 65189 Wiesbaden
Tel: 0611-1408-0, Fax: 0611-1408-900
www.datenschutz.hessen.de
Poststelle@datenschutz.hessen.de

MainSky Asset Management AG receives personal data from clients and other business partners in the course of contract initiation and fulfillment. Within the scope of our administrative activities we also receive data from the custodian banks selected by you. Furthermore we process personal data from publicly accessible sources, e.g. telephone directories, internet.

Possible data categories

1. Names/Contact details
2. Identity card data
3. Bank details
4. Creditworthiness data
5. Asset data
6. Order data
7. Invoice data
8. Payment details
9. Control data
10. curriculum vitae
11. Qualification data
12. Insurance data
13. Marital status and situation
14. Interests/preferences/special life circumstances
15. Plans and goals for the personal and professional future
16. Company contact details

We process your personal data in accordance with the EU-DSGVO for specific purposes and limited to the necessary extent.

Conceivable processing purposes

1. Contract initiation and conclusion
2. Fulfilment of contract
3. Master data maintenance
4. Creation of an investment strategy
5. Creation of a suitability concept
6. Order processing
7. Payment transactions on behalf of customers
8. Order processing
9. Phone recording
10. Handling of electronic communication
11. Strengthening customer loyalty
12. Sending a newsletter
13. Applications
14. Prevention of criminal offences
15. Compliance with higher-level legal regulations, especially those for financial services institutions (e.g. KWG, WpHG, various EU regulations and directives)
16. Protection of legal claims

We process your personal data in accordance with the Basic Data Protection Regulation (EU-DSGVO) and the Federal Data Protection Act (BDSG).

• Insofar as the processing of personal data is carried out for the purpose of fulfilling contractual obligations with you, Art. 6 para. 1 lit. b. DSGVO is the corresponding legal basis..
• Insofar as necessary, we process your data beyond the actual fulfilment of your contract in order to protect the legitimate interests of us or third parties (Art. 6 para. 1 lit. f. DSGVO).
• Insofar as you have given us your consent to process personal data for specific purposes, the processing will be based on your consent (Art. 6 para. 1 lit. a. DSGVO).

In addition, we are subject to various legal obligations (Money Laundering Act, Tax Act, etc.) as well as banking supervisory regulations. For this purpose (Art. 6 para. 1 lit. c DSGVO) data processing may also be necessary.

Within MainSky Asset Management AG those departments receive your data, which need them to fulfill our contractual and legal obligations. Also contract processors employed by us (Art. 28 DSGVO) may receive data for these purposes. Depending on the nature of the contractual relationship entered into, data may be transferred to other recipients, for example public bodies or institutions (BaFin, Bundesbank, tax authorities, etc.) if there is a legal obligation.

A data transfer to countries outside the EU or the EEA (so-called third countries) takes place in accordance with Art. 44 ff. DSGVO, data will only be transferred to countries outside the EU or EEA (so-called third countries) if this is necessary to execute your orders (e.g. payment or securities orders), if it is required by law (e.g. tax reporting obligations) or if you have given us your consent. If third party service providers are used, they are obliged to comply with the level of data protection in Europe in addition to written instructions by the agreement of the EU standard contract clauses.

We process (and store) your personal data to fulfill our contractual and legal obligations or for the purpose for which you provide us with the data. As soon as the processing purpose ceases to apply, this data is regularly deleted, unless its temporary further processing is necessary for the following purposes.

• Fulfilment of commercial and tax law retention periods: The German Commercial Code (HGB), the German Fiscal Code (AO), the German Banking Act (KWG), the Money Laundering Act (GwG) and the Securities Trading Act (WpHG). The periods of retention or documentation stipulated therein range from two to ten years.
• Preservation of evidence within the scope of the statute of limitations. According to §§ 195ff of the German Civil Code (BGB), these limitation periods can be up to 30 years, whereby the regular limitation period is three years.

very person concerned has the right to

• Information about processing of personal data according to Art 15 EU-DSGVO,
• Revocation of a granted consent according to Art. 7 EU-DSGVO
• Correction according to Art. 16 EU-DSGVO,
• Deletion according to Art. 17 EU-DSGVO,
• Restriction of processing according to Art 18 EU-DSGVO,
• Objection to processing on the basis of a legitimate interest according to Art. 21 EU-DSGVO and
• Data transferability according to article 20 EU-DSGVO.

The restrictions according to §§ 34 and 35 BDSG apply to the right of information and deletion. In addition, you are entitled to lodge a complaint with the Hessian data protection supervisory authority (Art. 77 EU-DSGVO in conjunction with § 19 BDSG).

In particular, we are obliged under money laundering law to identify you before establishing the business relationship, for example by means of your identity card, and to record and record your name, place and date of birth, nationality and residential address. To enable us to comply with this legal obligation, you must provide us with the necessary information and documents in accordance with the Money Laundering Act and notify us immediately of any changes that occur during the course of the business relationship. As a financial services institution subject to the supervision of the Federal Financial Supervisory Authority, we are legally obliged to process certain data when providing financial services (e.g. financial portfolio management, investment advice, investment and acquisition brokerage).

Within the scope of our business relationship, you must therefore provide us with those personal data which are necessary for the establishment and execution of a business relationship and the fulfilment of the associated contractual obligations or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or execute the order, or be unable to execute an existing contract and may have to terminate it. If you do not provide us with the necessary information and documents, we may not commence or continue the business relationship requested by you.

We do not use automated decision making according to Art. 22 EU-DSGVO.

The data controller collects and processes the personal data of applicants for the purpose of processing the application procedure. The processing may also be carried out by electronic means. This is particularly the case if an applicant submits relevant application documents to the data controller by electronic means, for example by e-mail or via a web form on the website. If the data controller concludes an employment contract with an applicant, the transmitted data is stored for the purpose of processing the employment relationship in compliance with the statutory provisions.

If the data controller does not conclude an employment contract with the applicant, the application documents shall be automatically deleted six months after notification of the rejection decision, unless deletion is contrary to any other legitimate interests of the data controller. Other legitimate interests in this sense include, for example, a duty of proof in proceedings under the General Equal Treatment Act (AGG).

If your personal data is processed by us on the basis of legitimate interests in accordance with Art. 6 Par. 1 S. 1 lit. f DSGVO, you have the right, in accordance with Art. 21 DSGVO, to object to the processing of your personal data if this is done for reasons arising from your particular situation. In the event of an objection, we will no longer process your personal data unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

The objection can be made without formality and should be addressed to

Data Protection Coordinator
MainSky Asset Management AG
Reuterweg 49, 60323 Frankfurt am Main
Tel: 069-15049680-0
datenschutz@mainsky.de

When you view our website, general information is automatically collected using a cookie. This information (log files or server log files) describes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider and similar. This data is collected by the Internet service that hosts our website. They are technically necessary in order to display the contents of the website correctly and are always collected when you move around the Internet. They are processed in particular for the following purposes:

1. Ensuring that the website can be connected without problems.
2. Ensuring a smooth use of our website.
3. Evaluation of system security and stability.

According to the Internet host, the data of the log files are anonymized after 7 days and stored for a maximum of 8 weeks. Anonymous information of this kind can also be statistically evaluated by us in order to optimize our website and the technology behind it.

Due to our legitimate interest, this processing of your personal data is permitted. We do not use your data to draw conclusions about your person. Recipients of the data are only MainSky Asset Management AG as the responsible body and the Internet host.

The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f DSGVO (legitimate interest). With the tracking measures we use, we want to ensure a needs-based design and the ongoing optimization of our website. On the other hand, we use the tracking measures to record the use of our website statistically and evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as justified in the sense of the above-mentioned regulation. The respective data processing purposes and data categories can be taken from the corresponding tracking tools.

This website is programmed in HTML5 and offers you the advantage of a responsive design. With the help of the computer language used, we have created several pages of the same content, which allows you to view our offer on different devices (desktop computer, tablet, smartphone). No cookies are used for device width recognition! Your device only transmits technical data and browser information, from which the programming derives a percentage for the display. This information is not linked and stored with personal information, but queried anew at each visit. Your device will not be recognized.

This site uses SSL or TLS (Transport Layer Security) encryption for security reasons and to protect the transmission of confidential content. You can recognize the use of this data transmission security by the small lock symbol in the upper left corner of the browser and the use of the scheme "https" (instead of "http") as part of our internet address. If the SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

If you have agreed, we will send you our newsletter or comparable information on a regular basis to the e-mail address you provide us for this purpose. Subscribers can also be informed by e-mail about circumstances relevant to the service or registration (for example, changes to the newsletter offer or technical conditions).

For an effective registration we need a valid e-mail address. In order to verify that the registration is actually made by you, we use a "double opt- in" procedure. For this purpose, we log the ordering of the newsletter, the sending of our confirmation mail your answer to it. We do not collect any further data. The data will be used exclusively for sending the newsletter and will not be passed on to third parties.

You can revoke your consent to receive the newsletter at any time. You will find a corresponding link in every newsletter. You can also inform us of your wish by using the contact option at the end of this data protection notice.

If you send us inquiries via contact form or e-mail, your details from the inquiry form or your e-mail, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. The indication of an e-mail address is required for contact purposes, the indication of your name and your telephone number is voluntary. Under no circumstances will we pass on this data without your consent.

The legal basis for the processing of the data is our legitimate interest in answering your request in accordance with Art. 6 para. 1 lit. f DSGVO and, if applicable, Art. 6 para. 1 lit. b DSGVO, if your request is aimed at the conclusion of a contract. Your data will be deleted after the final processing of your inquiry, provided that there are no legal obligations to keep records.

In the case of Art. 6 para. 1 lit. f DSGVO, you can object to the processing of your personal data at any time.

We use Google Maps for embedding maps. Here we connect to servers of Google Ireland Ltd. via an interface (API). At least IP address, URL (Internet address) of our website and date/time of use are transmitted to Google. Legal basis for the transmission is our contract with Google Ireland Ltd. (https://www.google.com/intl/de_US/help/terms_maps.html) according to Art. 6 para. 1 lit. b) DSGVO in connection with a contract on joint responsibility according to Art 26 DSGVO, which you can download here: https://privacy.google.com/intl/de/businesses/mapscontrollerterms. In this respect, visitors enter into a direct user relationship with Google when using Google Maps. Further information on this can be found in Google's detailed privacy policy https://www.google.com/policies/privacy.

We reserve the right to adapt or update this data protection declaration if necessary in accordance with the applicable data protection regulations. In this way, we can adapt it to current legal requirements and take into account changes in our services, e.g. when introducing new services. The most recent version applies to your visit.

Status of the data protection declaration: 01 November 2019

If you have questions regarding data protection concerning MainSky Asset Management AG, our data protection coordinator can help you:

MainSky Asset Management AG
Data protection coordinator
Reuterweg 49
60323 Frankfurt am Main

Tel: 069-15049680-0, Fax -29
e-mail: datenschutz@mainsky.de

The competent supervisory authority depends on the state of your residence, your work or an alleged data protection violation. A list of the supervisory authorities (for the non-public sector) with their addresses can be found at
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html