Data Protection

Name and address of the party responsible for processing

For purposes of this data protection notice, the party responsible for processing is the legally independent company of the Sauren Group whose business activities result in the respective processing activity. The responsible parties in this context are:

Sauren Fonds-Service AG
Im MediaPark 8 (KölnTurm), 50670 Cologne (Germany)
Tel.: 0221/ 65050 100, Mail: info@sauren.de
www.sauren.de

Sauren Finanzdienstleistungen GmbH & Co. KG
Im MediaPark 8 (KölnTurm), 50670 Cologne (Germany)
Tel.: 0221/ 65050 100, Mail: info@sauren.de
www.sauren.de

Sauren Fonds-Research AG
Im MediaPark 8 (KölnTurm), 50670 Cologne (Germany)
Tel.: 0221/ 65050 100, Mail: info@sauren.de
www.sauren.de

The joint data protection officer, Ms Ariane Rack, can be reached via datenschutzbeauftragter@sauren.de.

Collection and processing of data

On accessing Sauren Financial Group web pages and calling up a file stored on these web pages, data is automatically transferred to our web servers for technical reasons. On each query (e.g. accessing a page) the web servers save data. Data such as date and time of access to the web pages, URL of the linking web page, file called up, quantity of data sent, browser type and version and operating system are logged. The IP address of the computer originating the query is also logged. The Sauren Financial Group uses this data only for standard statistical reports (e.g. determining the number of visitors to the web pages). Other personal data is only collected if you, as a user of the web pages, provide the information voluntarily in the course of using the web pages. We also process personal data that we receive from customers or other relevant parties in the context of our business relationships.

If you send us an email or contact us using our contact form, your email address and other contact details are only stored and used for purposes of corresponding with you or sending any requested informational material.

Use of personal data and legal basis

If you, as a user of Sauren web pages, voluntarily provide personal or business data in the context of an enquiry or registration, this data is used to enable the provision of services offered on the web pages, e.g. to answer enquiries or send requested informational material. The personal data collected in forms for registration and contact requests is used exclusively for these purposes. It is not visible or transmitted to third parties outside the Sauren Financial Group unless you have given your prior consent.

If you use the contact form to contact us, your data is stored for the purpose of processing your enquiry and any subsequent questions. You must provide a valid email address and your name so that we know who has sent the enquiry and we are able to answer it. Other information may be provided voluntarily. This data is not transmitted to third parties outside the Sauren Financial Group unless you have given your prior consent.

The Sauren newsletter keeps you informed of current topics. On subscribing to the newsletter, the data you provide such as name, address, email address and similar is stored and used to send the newsletter. In general, you need only provide an email address in order to receive the newsletter via email. Other information may be provided voluntarily. It is possible to unsubscribe at any time, for example by sending a message to info@sauren.de. The data you provided such as name, address, email address and similar will not be transmitted to third parties outside the Sauren Financial Group in this case. For the use of short links within the Sauren newsletter or other mailings, please see the section "Use of Cuttly".

Data is also processed for purposes of service provision by the companies of the Sauren Financial Group in the context of a contractual relationship with the relevant party, or of implementation of pre-contractual measures subsequent to an enquiry.

If a person provides consent for the processing of personal data, for example in the case of newsletter subscriptions, requests for promotional material regarding Sauren funds of funds or the transmission of data within the Sauren Financial Group, this is governed by the legal basis of Art. 6 (1) (a) of the General Data Protection Regulation (GDPR).

For the processing of personal data required to execute a contract to which the relevant person is party, the legal basis is Art. 6 (1) (b) GDPR. This also applies for processing activities required to implement pre-contractual measures.

If the processing of personal data is necessary to satisfy a legal requirement to which our company is subject, or if it is in the public interest, the legal basis is Art. 6 (1) (c) and (e) GDPR. The latter applies, for example, if Sauren Finanzdienstleistungen GmbH & Co. KG or Sauren Fonds-Service AG, as a financial services institution or financial investment intermediary, is subject to special statutory or legal requirements, for instance under the German Securities Trading Act, German Securities Institutions Act, German Money Laundering Act, German Ordinance on Financial Investment Intermediaries or other regulatory requirements.

If data processing is necessary to safeguard the legitimate interests of our company or a third party (e.g. advertising, transmission of data within the corporate group, assertion of legal claims, safeguarding of IT security, measures related to business management and the further development of services and products) and if the interests and basic rights and freedoms of the person affected do not supersede the above-mentioned interests, the legality of data processing is assured by Art. 6 (1) (f) GDPR.

Secure data transmission

The Sauren Financial Group web pages are protected by SSL encryption (https://) against third-party access.

Use of cookies

Our website uses cookies. These are small files, automatically created by your browser, which are stored on your end device (laptop, tablet, smart phone or similar) when you visit our website. Cookies do not harm your device and do not contain viruses, Trojan horses or other malware.

A cookie stores information related to the specific end device in use. This does not mean, however, that we are directly made aware of your identity.

One reason for using cookies is to provide a more pleasant experience when you use our services. We therefore use “session” cookies to recognise which individual pages of our website you have already visited. These are then automatically deleted after you leave our website.

For purposes of enhanced user-friendliness, we also use temporary cookies that are stored on your end device for a predetermined period.

The data processed via cookies is necessary for the aforementioned purposes of safeguarding our legitimate interests and those of third parties in accordance with Art. 6 (1) (f) GDPR.

Most browsers accept cookies automatically. You can configure your browser in such a way that no cookies are stored on your computer or a notice always appears before a new cookie is set. However, if you deactivate cookies entirely, you may not be able to use all of the functions on our website.

Use of Google Analytics 4

In order to ensure that our websites are designed to meet the needs of our users and are optimised on an ongoing basis, we use Google Analytics 4, a web analysis service offered by Google LLC, 1600 Amphitheatre Parkway Mountain View, California 94043, USA, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter referred to as “Google”. This involves the creation of pseudonymous user profiles and the use of cookies. The cookie-generated information about your use of this website, such as

• browser type/version,
• operating system used,
• referrer URL (previous page visited),
• host name of the accessing computer (IP address),
• time of the server request

With regard to the transfer of data to the US, there is an EU adequacy decision on the EU-US Data Privacy Framework in place. Google LLC is registered under the Data Privacy Framework, so that an adequate level of protection can be assumed for the transfer of data to the US. In addition to that, reference is made to standard contractual clauses of the European Union. For more information, please see the provider's privacy policy at https://www.google.de/intl/de/policies/privacy.

We also use the "Google Signals" function of Google Analytics 4. By analyzing visited content, statistics can be created that provide information about the age, gender and interests of page visitors. However, the collected data cannot be assigned to a specific person by us and the raw data is generally deleted after a storage period of two months.

This information is used to analyse usage of the website, compile website activity reports and provide other services related to website and Internet usage for purposes of market research and the needs-based design of such websites. This information may also be transmitted to third parties if required by law or if third parties are contracted to process this data. Under no circumstances is your IP address associated with other Google data. IP addresses are anonymised to prevent attribution (IP masking).

You can prevent the installation of cookies by changing the relevant setting in your browser software; however, it should be noted that it may not then be possible to use all of the functions of this website to their full extent.

You can also opt out of the communication to Google of data collected by the cookie in connection with your use of the website (including your IP address) and the processing of such information by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially when using browsers on mobile devices, you can also prevent information from being communicated to Google Analytics 4 by clicking on this link:

(https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially when using browsers on mobile devices, you can also prevent information from being communicated to Google Analytics by clicking on this link:

Deactivate Google Analytics

An opt-out cookie is placed which prevents future logging of your data when visiting this website. The opt-out cookie, which is stored on your device, only applies in this browser and only for our website. If you delete the cookies in this browser, you must set this opt-out cookie again.

Use of Google Tag Manager

We use Google Tag Manager. This is a service of Google LLC, 1600 Amphitheatre Parkway Mountain View, California 94043, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool for organizing, managing and integrating tags on our website. Tags are sections of code that are used for analysis, tracking and marketing purposes, for example. These tags of the respective tools come, for example, from services provided by Google LLC itself, such as Google Analytics. The tags may also originate from other companies. Cookies can be set and loaded via the Google Tag Manager; the Google Tag Manager itself does not collect any personal data. The Google Tag Manager consists of program code that is (however) loaded from a Google server like a normal website request. The IP address is transmitted, but not (further) processed by Google and will be deleted after 14 days. In this context, please refer to the following information provided by Google: https://support.google.com/tagmanager/answer/9323295?hl=de.

The tools loaded by Google Tag Manager can, among others, set cookies and process data. The tools we use are described in this Data Protection Notice. Data is also processed by Google in the US. Please refer to the adequacy decision on the EU-US data protection framework (Data Privacy Framework) and standard contractual clauses of the European Union. For more information, please see https://www.google.de/intl/de/policies/privacy. 

Use of YouTube

We use YouTube to be able to display videos on our websites. YouTube is a video portal offered by YouTube LLC, 901 Cherry Ave., 94066 San Bruno, CA, USA. YouTube LLC is, in turn, a subsidiary of Google LLC, 1600 Amphitheatre Parkway Mountain View, California 94043, USA. Responsibility for providing certain services, such as YouTube, has been assumed by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. 

With regard to the transfer of data to the US, there is an EU adequacy decision on the EU-US Data Privacy Framework in place. The provider of the aforementioned service is registered under the Data Privacy Framework, so that an adequate level of protection can be assumed for the transfer of data to the US. In addition to that, reference is made to standard contractual clauses of the European Union. For more information, please see the provider's privacy policy at https://www.google.de/intl/de/policies/privacy.

In the interests of functionality and to analyse user behaviour, YouTube LLC stores cookies permanently on your end device via your internet browser. If you do not agree to this processing, you can opt to configure your internet browser settings so as to prevent cookies from being stored.

Use of Vimeo

We use “Vimeo” to show videos on our website. This is a service offered by Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA.

In some cases, user data is processed on Vimeo’s servers in the US. Data transfer to Vimeo LLC is based on standard contractual clauses of the European Union. For more information, please visit https://vimeo.com/privacy#international_data_transfers_and_certain_user_rights.

If you visit websites with embedded videos, a connection is established with Vimeo LLC’s servers in the US in order to display the video. Vimeo LLC has to process your IP address for technical reasons so that it can display the video. Information is also, however, recorded on the date and time of your visit to our websites.

If you do not agree to this processing, you can opt to configure your internet browser settings so as to prevent cookies from being installed.

Use of Cookiebot

In order to provide a comprehensive cookie notice to users of our website, we use Cookiebot. This software is provided by Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark. By using this feature, data from you may be sent to, stored and processed by Cookiebot or Usercentrics. In this context, data is also stored on servers in the USA. In this context data transfer is based on standard contractual clauses of the European Union.

For more information, please refer to the provider's privacy policy at https://www.cookiebot.com/de/privacy-policy/.

Use of Cuttly

Cuttly is an URL shortener with link analytics, provided by Web Room Studio Patryk Ruminski, located at ul. Śląska 15A/9, 80-384 Gdańsk, Poland.

Our newsletter or other mailings may contain links to further content such as video recordings, webinars or podcasts on the Sauren website www.sauren.de or external websites. We use short links for this purpose. When following such a short link, the aforementioned provider only generates anonymous statistics. No data such as the IP address is stored permanently. It is only transmitted briefly to determine the geo-location (country). It is not possible to identify a person based on statistics. These are merely anonymous statistics.

There is no data transfer to a third country outside the EU. The use of Cuttly as a service for shortening the URL and an anonymous evaluation of link usage is intended to ensure a visually appealing design of our newsletter and other mailings. Furthermore the aim is to improve the use and to provide targeted information. A permanent storage of personal data does not take place. 

For more information, please refer to the provider's privacy policy at https://cutt.ly/privacy.

Use of storytile

We use a participant management software for an optimized implementation of web seminars.

This is a software service provided by storytile GmbH, Gollierstr. 70, 80339 Munich, Germany.

In addition to the common functions for preparing and conducting a webinar (e.g. registration, participant management, etc.), there are also statistical evaluations of the behaviour of webinar participants on the webinar portal.By using the webinar software, personal data may be sent, stored and processed to storytile GmbH or, under certain circumstances, to service providers used by the latter. With regard to the transfer of data to the US, there is an EU adequacy decision on the EU-US Data Privacy Framework in place certain service providers areregistered underThat means an adequate level of protection can be assumed for the transfer of data to the USA. In addition to that, reference is made to standard contractual clauses of the European Union. For more information, please see the providers´ privacy policy at https://www.storytile.net/datenschutzerklaerung.

Duration of data storage

The duration of personal data storage is normally determined by legal retention requirements. Under commercial and tax law, retention requirements are generally six to ten years. Statutory limitation periods may be up to 30 years but are generally three years. Data is regularly deleted when it is no longer required for contractual or other purposes.

Right to lodge a complaint with a supervisory authority

Irrespective of any other administrative or judicial appeals, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your usual place of residence, place of work or place of the alleged infringement if you consider that the processing of your personal data violates the GDPR.

The supervisory authority to whom the complaint is submitted shall inform the appellant of the status and outcome of the complaint, including the possibility of submitting an appeal, in accordance with Art. 78 GDPR.

Use of contact data

The third-party use of contact information published on the basis of the disclaimer requirement in order to send unauthorised advertisements and informational material is hereby explicitly prohibited. The site administrator explicitly reserves the right to take legal action if promotional information is sent on an unsolicited basis, for example through spam mails, etc.