Privacy Policy

Privacy Policy

We are pleased to welcome you as cooperation partner at wefox. In the following we would like to give you some information regarding the data processing of our cooperation partners at wefox.

Notes on the Use of the Date Protection Information

The General Data Protection Rules (GDPR) are in principle applicable solely to individuals and not to entities. Therefore, the present privacy policy only applies to individuals such as independent agents who do not act as entities.

Legal entities such as a limited liability company or partnerships are not subject to the GDPR. Therefore, the present privacy policy does not have to be complied with in respect of such entities. In certain cases, however, it may be possible that the reference to individuals also applies to entities, such as a one-person limited liability company or individual companies. In cases of doubt, the present information obligations will therefore also have to be fulfilled vis-à-vis these legal entities.

It should furthermore be noted that some member states of the European Union have provided for their own corporate personality protection. This is the case, for example, in Austria, Denmark, Italy and Luxembourg, but not in Germany. For this reason, the present information obligations must also be fulfilled with regard to the onboarding of cooperation partners which are subject to the corresponding protection of corporate personality in these member states.

1. Purpose of Data Processing

1.1. Within the framework of the terms and conditions for the brokerage portal, we enable you to communicate to your customers. In order to fulfill our services foreseen in the terms and conditions for the brokerage portal, it is necessary for us to process your personal data. For this purpose, we collect personal data directly from you and from publicly available sources.

1.2. We process your data within the framework of the data protection regulations, if necessary, also for purposes that are not directly related to the processing purpose of our services included in the terms and conditions for the brokerage portal. Such purposes may, for example, arise from tax law or the Money Laundering Act (Geldwäschegesetz).

2. Name and Address of the Controller

2.1. Controller within the meaning of the data protection regulations is:

wefox Germany GmbH
Represented by its managing directors
Urbanstrasse 71
10967 Berlin

 

2.2. The data protection officer of the controller is:

Data Protection Officer of wefox
Urbanstrasse 71
10967 Berlin

3. Types of Personal Data

3.1. In order to perform our services as included in the terms and conditions for the brokerage portal, we collect in particular the following personal data directly from you and process them in accordance with the terms and conditions for the brokerage portal: [Surname, Name], [Address], [Communication Data (telephone, e-mail address)].

3.2. Furthermore, we collect and process your personal data from publicly accessible sources, such as the register of intermediaries.

4. Cookies

4.1. Our website uses cookies. Cookies are small text files which are stored by your browser in your device’s memory and provide us with specific information. Cookies cannot run programs nor deliver viruses to your computer. They serve to make our site more user-friendly and effective.

4.2. In the following you will find information about cookies, how we use them on our website and what options you have if you prefer to disable these cookies, despite their advantages. If you neither disable the cookies nor use the option of the opt-out function as described below, we assume that you accept the use of cookies.

 If you have any questions about the individual cookies and their functions, you can contact us at

 

wefox Germany GmbH
Urbanstraße 71
10967 Berlin
Email: [email protected]

 

4.3. This website uses cookies, which are described hereinafter, in order to improve user-friendliness: Cookies which are necessary for technical reasons for the function of our website or offer a service or option which you have requested; e.g. a cookie which “remembers” your personal settings, such as selected language or the like.

4.4. We strive to constantly improve our website. Cookies are used for this purpose, which provide us with overall statistics about the number of visitors, which areas of a site are viewed the most, details about the city or location of the users as well as the duration of the visit etc. These can be installed by external analysis providers which we commission.

4.5. On certain pages of our website, we use cookies to better understand your interests when using the Internet. We can therefore offer you a service adapted to your needs in the future. These cookies collect information about where you started your visit, whether you have been shown wefox contents, which concrete advertising material you have viewed, whether you accessed our website directly or indirectly, which device you used to visit our website and what you have downloaded.

4.6. You can also use our website without cookies. To prevent your internet browser using cookies, you can disable the use of cookies via your internet browser settings. Furthermore, cookies that have already been set can be deleted at any time using an internet browser or other software programs. This is possible in all common internet browsers. You can find out how to disable and/or delete cookies using your internet browser’s help function. Please be aware that disabling/deleting cookies can lead to some features of our website no longer working as expected. Cookies which could be required for certain features of our website are set out below. In addition, disabling/deleting the cookies only applies to the internet browser currently in use. If you use other internet browsers, the process of disabling/deleting cookies needs to be repeated accordingly.

4.7. We store these data until the end of the duration of a given cookie or until you have deleted the cookies.

4.8. You can find out about further processing of personal data using cookies in the corresponding sections of this privacy policy.

4.9. We use your information as part of website analysis in order to make our website more user-friendly and to be able to conduct market research. We use website analysis tools for this purpose. These tools use your IP addresses either in truncated form or not at all. Analysis cookies of this type are set on the basis of Art. 6 para. 1 lit. f GDPR. As the operator of this website, we have a legitimate interest in analyzing user behavior in order to optimize our website.

 

  • Google Analytics

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

Google Analytics uses cookies, which are stored on your computer and facilitate the analysis of user behavior when visiting the website. We use Google Analytics in conjunction with the IP anonymization function. In this case, the IP address is truncated within the European Economic Area prior to transmission to the United States. The IP address is only truncated in the USA in exceptional cases. On our behalf, Google will use this information for the purpose of evaluating your use of the website, for compiling reports on website activity, and for providing us with other services relating to website activity and internet usage. The IP address transmitted by Google Analytics is not conflated with other Google data.

You can prevent the installation of cookies by changing your browser settings accordingly. You can also prevent Google collecting and processing the information generated by the cookie about your use of this website (including your IP address) by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For such exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

4.10. We further use your information to show you advertising which is tailored to you and your interests. To this end, we use the following tools which use your IP address (in truncated or else full form) for these purposes. The legal basis for using this data is Article 6 para. 1 lit. f GDPR. As operator of this website, we have a legitimate interest in displaying product recommendations and carrying out marketing activities. Learn more about the tools which we use for this purpose.

 

  • Facebook Pixels/Custom Audiences

We use the function “Facebook Custom Audiences” which is operated by the company Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland (”Facebook”). Thanks to this technology, users, who have already visited our website and been interested in what is on offer, are targeted once again by targeted advertising on Facebook via adverts which are shown. The advertising is shown by using cookies, with the help of which user behavior when visiting the website can be analyzed and subsequently used for targeted product recommendations and interest-based advertising. Information about the activities of the user on the website, such as surfing behavior and subpages visited etc. is collected.

You can find more information at https://www.facebook.com/about/privacy/.

You can disable the Custom Audiences feature at https://www.facebook.com/settings?tabR=ads. For this, you will first of all have to register.

Facebook has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, in order to guarantee a sufficient level of data protection for your data.

 

  • Google AdWords Conversion Tracking

wefox uses the online advertising offer from Google “Google AdWords” and conversion tracking as part of Google AdWords. Google Conversion Tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). A conversion tracking cookie is stored on your computer if you click on an advertisement placed by Google. These cookies are no longer valid after 90 days and do not contain any personal data. If you visit certain pages of our website and the cookie has not yet expired, Google and the website can tell that you clicked on the ad and proceeded to that page. Each Google AdWords advertiser has a different cookie. The information obtained using the conversion cookie is used to generate conversion statistics for us. Here, we only see the total number of anonymous users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, they do not obtain any information which can be used to identify users personally.

You can disable personalized advertising for you in the advertising settings for Google at http://www.google.de/settings/ads.

You can find more information about how your data is handled at https://policies.google.com/privacy?hl=de&gl=de.

 

  • Google Doubleclick

Google retargeting uses so-called double click cookies. This allows adverts to be proposed, optimized and evaluated for you based on your previous visits to this website, by information about your browsing behavior being collected and stored for marketing purposes using a pseudonym. Based on this, you can then be shown targeted product recommendations as ad banners on other websites. We will under no circumstances link this information with data from your customer relationship or use the data to personally identify you as visitor of this website. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, in order to guarantee a sufficient level of data protection when processing your data in the exceptional cases in which your data are processed in the USA.

You can prevent Google/DoubleClick collecting usage data by following the instructions at the following link: http://www.google.de/settings/ads.

 

4.11. On our website we also use a web service from the company Cloudflare Inc., 101 Townsend St, 94107 San Francisco, USA (hereinafter: CloudFlare), to make our website faster and more secure. For this purpose, Cloudflare collects your information, such as IP addresses, system configuration information and other information regarding the traffic from and to the website as well as log data. These data help us detect new threats and access by unauthorized third parties. Legal basis for data processing is Art. 6 para. 1 letter f GDPR. The legitimate interest lies in an error-free and secure function of our website.

 

  • Cloudflare

Cloudflare has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, in order to guarantee a sufficient level of data protection when processing your data in the USA.

You can find further information about how Cloudflare handles your data at https://www.cloudflare.com/de-de/privacypolicy/.

 

  • LogEntries

In addition, wefox uses the service “LogEntries”, which is operated by RAPID7, The One Building, 2nd Floor, 1 Grand Canal Street Lower, Dublin 2, Dublin, Ireland, in order to evaluate the log files. In this case, log files (such as IP address, operating system used, name of the Internet service provider) are transferred to log entries, in order to evaluate them anonymously. They are evaluated in order to ensure the functionality of the website. Furthermore, the data is used to optimize the website and to ensure the safety of our information technology systems. The data is not evaluated for marketing purposes in this context. Therefore, processing takes place for these legitimate interests, Art. 6 para. 1 lit. f GDPR. You can find further information in this regard at: https://logentries.com/privacy/.

Data processing also takes place in the United States here. A suitable level of data protection is ensured by Rapid7 Inc’s participation in the EU-US Privacy Shield.

 

4.12. In addition, you can find links to social media networks such as Facebook, Twitter, Google+, YouTube and LinkedIn on our website. These are not social plug-ins provided by the social media provider which transfer data to the provider as soon as you load the page, without the user being able to have an influence over it. After clicking on the social media networks, there is simply a link to the social media network including the transfer of the website to be shared. No user data is transferred from the website to the social media network. If you are already registered with the corresponding social media service when you click on the button, the sharing dialogue recognizes this so that you can directly share the content. If this is not the case, you will be requested to log into the social media network. From that point, you’ll find yourself on the website of the respective social media network. You can find information on data processing of the respective providers below.

 

  • Facebook

Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland, operated (“Facebook”) You can find information on Facebook data protection here: http://www.facebook.com/policy.php. Facebook has also submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

  • Twitter

Twitter Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA. You can find further information and adjustment options at: https://twitter.com/privacy.

Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

  • Instagram

Instagram is a product provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, https://help.instagram.com/519522125107875.

Instagram has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

  • LinkedIn

LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; https://www.linkedin.com/legal/privacy-policy.

LinkedIn has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

 

  • XING

New Work SE, Dammtorstraße 30, 20354 Hamburg, https://privacy.xing.com/de/datenschutzerklaerung.

 

  • Intercom

Intercom offers messaging for sales, marketing, and customer service on a single platform and improves user interaction via chat. You can find information on data protection from Intercom Inc., 55 2nd St, San Francisco, CA 94105, USA; https://www.intercom.com.

5. With whom and how do we share your information?

5.1. wefox outsources certain processes and tasks to service providers in order to guarantee the handling of complicated topics, which require particular knowledge or cannot be undertaken inhouse or to be able to fulfil the contract with you, for example hosting our website, analyzing user behavior on our websites and so on. Therefore, we will pass on your data to the following categories of recipients:

  • Technical service providers which work for us
  • For web analysis and marketing purposes

5.2. Furthermore, data are also shared with the following specialized companies in the wefox group of companies in order to carry out central data processing tasks. In this case, your data may be processed centrally by a company of the group for the central management of address data, for the customer services help line, for the processing of benefits or for general mail handling. These companies include:

  • wefox Group services (GER) GmbH
  • FinanceFox Services BCN S.L.

In this case, we will only pass on such information to the companies which is necessary for the respective service. Information beyond this is not communicated to the companies.

5.3. In addition, in the context of your information being forwarded to other service providers, we would like to ensure that your data are handled carefully and that you are able to exercise your rights even when other service providers are involved. For this reason, corresponding contracts for protecting your information have been concluded with the service providers, wherever necessary.

5.4. Your personal data is communicated for the purpose of contract initiation or implementation with you on the basis of Art. 6 para. 1 clause 1 lit. b GDPR, owing to our legitimate interest, to keep our products functional and safe, on the basis of Art. 6 para. 1 clause 1 lit. f GDPR and provided that you have given us your consent for your personal data to be processed on the basis of your consent within the meaning of Art. 6 para. 1 sentence 1 lit. a GDPR.

5.5. Moreover, we communicate your personal data only to the extent that there is a statutory obligation for disclosure on our part. This communication is done on the basis of Art. 6 para. 1 sentence 1 lit. c GDPR (e.g. to the police authorities as part of criminal investigations or to the data protection supervisory authorities).

5.6. Your data are also partly processed in countries outside of the European Union (“EU”) or the European Economic Area (“EEA”). In these cases, we ensure with our contractual partners that a sufficient level of data protection is guaranteed for your data, e.g. by contractual arrangements (EU standard contractual clauses).

6. Legal Basis of the Data Processing

6.1. The personal data collected by us is necessary for the implementation of the terms and conditions brokerage portal. The legal basis for data processing is Art. 6 para. 1 lit. b of the General Data Protection Regulation (GDPR). The legal basis for the processing of data within the meaning of number 1 para. 2 of this privacy policy is Art. 6 para. 1 lit. f GDPR.

6.2. We only collect and process data that is necessary for the performance of the services included in the terms and conditions brokerage portal. If you do not provide the the required personal data, the services foreseen in the terms and conditions brokerage portal cannot be implemented.

6.3. With your consent, you can subscribe to our newsletter, which informs you about our other current products and services.

To subscribe to our newsletter, we use the so-called double opt-in procedure. This means that after your registration we will send an e-mail to the e-mail address you provide. This e-mail will ask you to confirm that you would like the newsletter to be sent. In addition, we will store your IP address and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

The only required information for sending the newsletter is your e-mail address. The provision of further, separately marked data is voluntary and is used to be able to address you personally. After your confirmation, we will save your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 para. 1 clause 1 lit. a GDPR.

6.4. You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can do so by clicking on the link provided in every newsletter email, by sending an email to [email protected], or by contacting us in one of the ways listed in the legal notice.

7. Distribution of Data to Third Parties

7.1. In order to perform the services included in the terms and conditions brokerage portal, it is required that we distribute your personal data to third parties. All third parties are subject to the requirements of the GDPR. In the appendix to this privacy policy you will find a list of third parties to which we distribute your personal data.

7.2. Depending on the third party, the legal basis for the distribution of data to third parties is Art. 6 para. 1 lit. b GDPR or Art. 6 Abs. 1 lit. f GDPR.

8. Duration for which Personal Data is stored

8.1. To the extent required, we will process your personal data for the duration of our business relationship. This may also be the initiation and processing of your data upon registration on the website. In addition, we are subject to various storage and documentation obligations. These result from the German Commercial Code (Handelsgesetzbuch, HGB), the German Fiscal Code (Abgabenordnung, AO) and the Money Laundering Act (Geldwäschegesetz, GwG). The periods of retention and documentation stipulated therein are five years (HGB), six years (AO) or ten years (HGB), depending on the document and law. To the extent processing of personal data is required to assert legally established claims or claims from enforceable settlements or enforceable deeds or titles, your personal data will be deleted after a maximum of thirty years.

9. Your Rights

9.1. Each cooperation partner has the right to information in accordance with Art. 15 GDPR, the right to correction pursuant to Art. 16 GDPR, the right to deletion pursuant to Art. 17 GDPR, the right to restriction of processing pursuant to Art. 18 GDPR, the right to objection pursuant to Art. 21 DSGVO and the right to data transferability pursuant to Art. 20 DSGVO.

9.2. With regard to the right of information and deletion, the restrictions pursuant to Art. 17 para. 3 GDPR and §§ 34 und 35 Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) apply.

9.3. You may also request that we provide any personal information you have provided to us in a structured, common, machine-readable format either to you or to a person or entity of your choice.

9.4. Further, a right of appeal to the competent supervisory authority exists, which is:

Berliner Beauftragte für Datenschutz und Informationssicherheit
Friedrichstr. 219
10969 Berlin

 

9.5. Pursuant to Art. 21 Abs. 1 GDPR you have the right to object at any time, for reasons arising from your own particular situation, to the processing of personal data relating to you, which is carried out pursuant to Art. 6 para. 1 lit. e GDPR (data processing in the public interest) or pursuant to Art. 6 para. 1 lit. f GDPR (data processing to safeguard a legitimate interest). In the event of an objection, we will no longer process your personal data unless we can prove compelling reasons for processing, which are worthy of protection and which outweigh your interests, freedoms and rights or the processing is made for the assertion, exercise or defense of legal claims.

9.6. To exercise your rights, please contact the person responsible for data protection or his data protection officer at:

Data Protection Officer of wefox
Urbanstraße 71
10967 Berlin
Email: [email protected]

 

10. Changes to this privacy policy

We reserve the right to update this privacy policy from time to time. Updates made to this privacy policy will be published on our website. Changes shall come into effect from the time of their publication on our website. We therefore recommend that you regularly visit this page in order to keep abreast of any possible updates.