DATA PROTECTION DECLARATION (INCLUDING LEGALLY REQUIRED INFORMATION CONTENT)
Part 1: Information on data protection regarding our processing under Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR)
We take data protection very seriously and inform you herein how we process your data and what claims and rights you are entitled to under data protection regulations. Applicable from 25 May 2018.
1. | Office responsible for data processing and contact data | |
Responsible office in the meaning of data-protection law |
Contact data of our data-protection officer: Data-protection officer Swiss Life Asset Managers Deutschland HEC Harald Eul Consulting GmbH Auf der Höhe 34 50321 Brühl E-Mail-address DSB-SwissLifeAssetManagers@he-c.de |
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2. | Purposes and legal foundations upon which we process your data We process personal data in accordance with the stipulations of the General Data-Protection Regulation (GDPR), the German Federal Data-Protection Act (Bundesdatenschutzgesetz – BDSG) and other applicable data-protection provisions (details are provided in the following). The details of which data are processed and how they are used depends largely on the services requested or agreed in each case. Further details or additions for the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provided to you (e. g. in the context of the use of our website or our terms and conditions). In addition, this data protection information may be updated from time to time, as you may find out from our website https://www.swisslife-am.com |
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2.1 |
Purposes pursuant to fulfilment of an agreement or pre-contractual measures (Art. 6, section 1 b of the GDPR) The processing of personal data is carried out in order to carry out our contracts with you and the execution of your orders as well as to carry out measures and activities within the framework of pre-contractual relations, e. g. with interested parties. In particular, the processing thus serves to provide Real-Estate Property Services, such as the
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Purposes within the framework of a legitimate interest on our part or of third parties (Art. 6, section 1 f of the GDPR) Above and beyond the actual fulfilment of the (pre-) agreement, we process your data whenever this is necessary to protect legitimate interests of our own or of third parties, in particular for the following purposes:
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2.3 |
Purposes within the framework of your consent (Art. 6, section 1 a of the GDPR) |
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2.4. | Purposes relating to adherence to statutory requirements (Art. 6, section 1 c of the GDPR) or in the public interest (Art. 6, section 1 e of the GDPR) Just like any actor which takes part in business life, we are also subject to a large number of legal obligations. These are primarily statutory requirements (e.g. commercial and tax laws), but also if applicable supervisory law or other requirements set out by government authorities. The purposes of processing may also include identity and age checks, prevention of fraud and money laundering (e.g. comparisons with European and international anti-terror lists), compliance with control and notification obligations under tax law as well as the archiving of data for the purposes of data protection and data security as well as for purposes of audits by tax advisors/auditors, fiscal and other government authorities. In addition, it may be necessary to disclose personal data within the framework of official government/court measures for the purposes of collecting evidence, law enforcement and criminal prosecution or the satisfaction of civil law claims. |
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3. | The categories of data that we process as long as we do not receive data directly from you, and its origin If necessary for the contractual relationship with you and the ac-tivities performed for you, we may process data which we lawful-ly receive from other offices or other third parties (e.g. quality assessment or complaints by customers/suppliers/consumers). In addition, we process personal data that we have lawfully col-lected, received or acquired from publicly accessible sources (such as, for example, commercial registers and association reg-isters, civil registers, the press, Internet and other media) if such is necessary and we are allowed to process this data in accord-ance with statutory provisions. Relevant personal data categories may in particular be:
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4. | Recipients or categories of recipients of your data At our company, your data is received by those internal offices or organisational units that need such to fulfil our contractual and statutory obligations or that require such data within the framework of processing and implementing our legitimate interests. Your data is disclosed/passed on to external offices and persons solely
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5. |
Length of time your data is stored |
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6. | Processing of your data in a third country or through an international organisation Data is transmitted to offices in countries outside the European Economic Area EU/EEA (so-called third states) whenever such is necessary to meet a contractual obligation towards you (e.g. if you are despatched to another country), such is required by law (e.g. notification obligations under tax law), such is in the legitimate interest of us or a third party or you have issued us your consent to such. At the same time, your data may be processed in a third country including in connection with the involvement of service providers within the framework of the processing of the order. If no decision has been issued by the EU Commission regarding the presence of a reasonable level of data protection for the respective country, we warrant that your rights and freedoms will be reasonably protected and guarantied in accordance with EU data-protection requirements through contractual agreements to this effect. We will provide you with detailed information on request. You can request information on the suitable or reasonable guarantees and the possibility, how and where to receive a copy of these from the company data-protection officer or the human resources department in charge of you. |
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7. | Your data-protection rights If certain conditions are met, you can assert your data-protection rights against us
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8. | Scope of your obligations to provide us your data You only need to provide data that is necessary for the commencement and performance of the business relationship or for a pre-contractual relationship with us or the collection of which we are required by law. Without this data, we are generally not able to conclude the agreement or continue to perform such. This may also relate to data that is required later within the framework of the contractual relationship. If we request data from you above and beyond this, you shall be informed about the voluntary nature of the information separately. |
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9. | Presence of an automated decision made in individual cases (including profiling)
We do not use any purely automated decision-making procedure as set out in Article 22 of the GDPR. If we do institute such a procedure in individual cases in the future, we shall inform you pursuant hereto separately if this is required by law Under certain circumstances, we may process your data in part with the aim of evaluating certain personal aspects (profiling). In order to provide you with targeted information and advice on products, we may use evaluation tools. These enable a needs-oriented product design, communication and advertising includ-ing market and opinion research. Such procedures can also be used to assess your solvency and creditworthiness as well as to combat money laundering and fraud. “Score values” can be used to assess your creditworthiness and creditworthiness. In the case of scoring, the probability is calculated using mathematical methods with which a customer will meet his payment obligations in accordance with the contract. Such score values thus support us, for example, in assessing our creditworthiness, decision-making in the context of product deals and are incorporated into our risk management. The calculation is based on mathematically and statistically recognised and proven methods and is based on your data, in particular income, expenditure, existing liabilities, profession, employer, length of service, experience from the previous business relationship, repayment of previous loans in accordance with the contract and information from credit agencies. Special categories of personal data according to Art. 9 GDPR are not processed. |
Information on your right of objection under Art. 21 of the GDPR
The objection can be filed without adhering to any form requirements and should if possible be sent to Swiss Life Asset Managers Deutschland GmbH Clever Str. 36 50668 Köln |
Our privacy policy and the information on data protection about our data processing according to article 13, 14 and 21 GDPR may change from time to time. All changes will be published on our website https://www.swisslife-am.com. Older versions can be viewed in an Archive.
Data protection information 13 April 2018
PART 2: SUPPLEMENTARY DATA PROTECTION INFORMATION FOR OUR WEBSITE
With the following data protection information, we would like to explain to you in more detail how your data is handled when you use our Websites.
1. | Visiting the website | |
1.1 |
Description and scope of data processing
This data is stored in the log files of our system. Storage together with other of your personal data does not take place on a regular basis. |
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1.2 |
Purposes of data processing The storage of the aforementioned data, in particular the IP address, by our systems is generally only temporary for the duration of the session and is necessary to enable the proper operation and display of the website. This processing of your data also serves the purposes of evaluating and continuing to ensure system security and stability, as well as other administrative purposes. Insofar as your data is stored in our log files, this is also only done for the reasons of ensuring the functionality of our websites. In addition, we use the data to optimize and ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. |
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Legal basis for data processing The legal basis for the processing and temporary storage of your personal data is Art. 6 para. 1 sent. 1 lit. f GDPR. Our legitimate interests follow from the purposes for data collection outlined. |
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1.4 |
Duration of storage In the case of storage of your data in log files, this is the case after seven days at the latest. Storage beyond this is only provided for in exceptional cases, for example if this is necessary for technical reasons or to improve our systems. In this case, the IP addresses of the users are deleted or alienated so that an assignment is no longer possible. |
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1.5 | Possibility of objection and removal The collection of your data for the provision of the website and the possible storage in log files is absolutely necessary for the operation of the website. Therefore, there is no possibility to object. |
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2. |
Contact form |
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2.1 | Description and scope of data processing A contact form is integrated on our website, which you can use to contact us. When using the contact form, the following data entered in the input mask is transmitted to us and stored:
In addition, your IP address and the date and time of the request are stored. For the processing of the data, your consent is obtained during the submission process and reference is made to this data protection information. The data will not be passed on to third parties. |
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Legal basis for data processing The legal basis for the processing of your data when using the contact form is your consent in accordance with Art. 6 para. 1 sent. 1 lit. a GDPR. |
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2.3 | Purposes of data processing The processing of personal data from the input mask is only used to process your contact request with us. The other personal data processed during the submission process serves to prevent misuse of the contact form and to ensure the security of our information technology systems. |
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2.4 | Duration of storage We will delete your data as soon as we no longer need it to achieve the purposes described. For the personal data from the input mask of the contact form, this is the case when the respective conversation with you has ended. The conversation is usually ended when the circumstances indicate that the reason for your contacting us has been conclusively clarified. |
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2.5 | Possibility of objection and removal You have the option to revoke your consent to the processing of personal data at any time. |
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3. | Electronic newsletter |
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3.1 |
Description and scope of data processing When sending our electronic newsletter, to which you can subscribe, we process the following of your personal data:
For sending the electronic newsletter, it is mandatory to provide the e-mail address. The processing of your further data serves the personalization of these contacts as well as the specialization of offers and information and is voluntary. |
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3.2 |
Purposes of data processing
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3.3 | Legal basis for data processing For sending our newsletter and further information to you, we will generally obtain your express declaration of consent. |
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Duration of storage We will delete your data as soon as we no longer need it to achieve the purposes outlined. |
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3.5 |
Possibility of objection and removal You can revoke your consent at any time and thus unsubscribe from receiving information about current and future products, services or other information about us. You can declare the revocation by clicking on the link provided in every newsletter e-mail or by sending a message to our contact details provided. If you object to the use of your data, we will no longer send you promotional communications. |
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General information on the use of cookies When visiting and using our website, cookies are stored on your computer. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that allows the browser to be uniquely identified when the website is accessed again. Some of them are essential, i.e. they are technically necessary for the operation of our website. Other cookies are used for statistical purposes or to analyze access to our website, or for marketing purposes or to offer you the use of external media. Both temporary/session cookies and longer stored cookies (so-called permanent cookies) are used. Temporary cookies are deleted again as soon as you close your browser. Permanent cookies remain for a longer period of time, but can be deleted manually at any time. Some of the cookies are placed by third parties. The legal basis for data processing when using essential cookies is Art. 6 para. 1 sent. 1 lit. f GDPR, when using all other cookies the legal basis is your consent according to Art. 6 para. 1 sent. 1 lit. a GDPR. Insofar as we do not process your data on the basis of your explicit consent, your personal data will only be processed to the extent necessary to protect our legitimate interests or the legitimate interests of a third party and to the extent that this does not override your interests or fundamental rights and freedoms that require the protection of personal data. Detailed information about the use of the respective cookies, in particular about their purpose, the respective functional duration and to what extent they are placed by third parties or third parties have access to the data collected via the cookies, can be found in our cookie banner on our website in addition to the present information of our data protection inormation. You can access this at any time by clicking on the icon at the bottom left of the screen. There you will also find, depending on the category of cookies used, detailed information on the legal basis for the respective data processing. You can consent to the use of the respective categories of cookies individually; you can change the consent you have given in each case in the cookie banner or revoke it from us at any time. |
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Links to other websites Our website may contain links to other websites. We have no influence on whether their operators comply with data protection regulations. We also have no influence on the legality of the content of these websites. Therefore, we reject any responsibility for the contents of other websites. |
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6. | Questions and comments For questions, suggestions or comments on the subject of data protection, please send an e-mail to info-slamde@swisslife-am.com. The rapid development of new internet technologies makes it necessary to adapt our data protection declaration from time to time. |