Privacy Statement

1. The company named in the legal notice (Imprint) of this website is the responsible body for this website within the meaning of the GDPR. The contact details provided there apply. You can contact our data protection officer at [email protected].
2. We collect personal data from visitors to our website for the purpose of providing and improving our online services and, in the broadest sense, for the purpose of promoting the sale of goods or services, including via our online presence(s), for compliance with legal obligations and for asserting/defending claims. This may include log files, your IP address and other personal data stored on your device. The legal basis for our data processing is Art. 6 (1) lit. f) GDPR within the scope of our aforementioned legitimate interests. If you have given us your consent to data processing, the legal basis for data processing is Art. 6 (1) lit. a) GDPR.
3. We delete the personal data collected from all users of the website as follows:
   

   Log files
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4. In the context of providing our online presence – but also in the context of sending email information with the appropriate consent – we use service providers, usually as processors. In this context, it cannot be ruled out that personal data may be transferred to non-EU/EEA countries. The transfer takes place either to third countries for which the European Commission has determined an adequate level of data protection or, if no adequate level of data protection is guaranteed, is usually based on the European Commission’s standard contractual clauses. Upon request, we will be happy to inform you which service providers we currently use, to which third countries personal data is exported and what measures we have taken to ensure an adequate level of data protection at the recipient.
5. You are not legally or contractually obliged to provide your personal data.
6. As a data subject within the meaning of the GDPR, you have the following rights vis-à-vis us:
   • Revocation of any consent given with effect for the future
   • Object to the processing of your personal data based on Art. 6(1)(f) GDPR
   • Information about the personal data we have stored about you in accordance with Art. 15 GDPR
   • Correction of incorrect personal data in accordance with Art. 16 GDPR
   • Deletion of your personal data stored by us in accordance with Art. 17 GDPR
   • Restriction of the processing of your personal data stored by us in accordance with Art. 18 GDPR
   • Transfer of your personal data stored by us in accordance with Art. 20 GDPR
   If you wish to exercise your above rights, please send us an email to [email protected] or contact us on +49 (0) 30 555 7929 10.
7. Of course, you also have the right to lodge a complaint with a supervisory authority. The supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information, www.datenschutz-berlin.de.

Special information about Google Analytics 4

1. Google Analytics 4: If you have given your consent to cookies, Google Analytics 4, a web analytics service provided by Google LLC, is used on this website. The responsible body for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
2. Type and purpose of processing Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by the cookies about your use of this website is usually transferred to a Google server in the USA and stored there.[OPTIONAL: We use the User ID function. With the help of the User ID, we can assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and analyse user behaviour across devices.][OPTIONAL: We use Google Signals. This allows Google Analytics to collect additional information about users who have enabled personalised ads (interests and demographic data), and ads can be delivered to these users in cross-device remarketing campaigns.]
   Google uses the information collected on our website to evaluate your [pseudonymous [NOT WHEN USING USER ID]] use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyse the performance of our website [OPTIONAL: and the success of our marketing campaigns].
3. In Google Analytics 4, the anonymisation of IP addresses is enabled by default. Due to IP anonymisation, your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. During your visit to the website, your user behaviour is recorded in the form of “events”, e.g. page views, number of visits to the website, start of session, websites visited, “click path”, interaction with the website, scrolls (whenever a user scrolls to the bottom of the page (90%)), your approximate location (region), your IP address (in abbreviated form), technical information about your browser and the devices you use (e.g. language settings, screen resolution), your internet service provider, the referrer URL (via which website/advertisement you came to this website).
4. Recipients: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as a processor pursuant to Art. 28 GDPR); Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA; Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
5. Third country transfer: The EU standard contractual clauses Controller-to-Processor apply.
6. Storage period: The data sent by us and linked to cookies is automatically deleted after 2 [OR: 14 months] . The maximum lifetime of Google Analytics cookies is 2 years. Data that has reached its retention period is automatically deleted once a month.
7. Legal basis: The legal basis for this data processing is your consent in accordance with 6 (1) (a) GDPR/Art. 6 (1) (f) GDPR .
8. Revocation
   You can change the setting of cookies at any time with effect for the future by calling up the cookie settings and changing your selection there. The legality of the processing carried out until the settings were changed remains unaffected. You can also prevent the storage of cookies from the outset by adjusting your browser software settings accordingly. However, if you configure your browser to reject all cookies, this may result in restrictions on the functionality of this and other websites. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by a.) not giving your consent to the setting of the cookie or b.) downloading and installing the browser add-on to deactivate Google Analytics HERE.
9. For more information on the terms of use of Google Analytics and data protection at Google, please visit https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.

GFORM (“us” or “we”) fully respects your right to privacy in relation to your interactions with this Website.
Whenever you use this Website, information may be collected through the use of cookies and other technologies. By using this Website, you agree to our use of cookies as described in the Cookie Notice.

Collection and Use of Information.
We will not collect any personal information about you on this Website without your prior consent.  We will let you know what we intend doing with your information before collecting it, so that you can decide whether or not to furnish that information to us.
If you choose to register with GFORM, we may need you to provide personal information to allow us to provide that particular service.  For example, you may need to provide the following information:

• Name;
• Email address;
• Telephone number; and
• The nature of the services required.

Any information which is provided by you will be treated respectively, securely and confidentially.
In addition to providing this information at the initial point of contact, and if you choose to correspond further with us through email or by phone, we may retain the content of your communications together with phone numbers, email addresses and our responses, as required by the Data Protection Acts.  We retain this information solely for the purpose of providing you with the relevant required services.
GFORM does not intentionally collect any sensitive information via this Website unless legally required to do so.  Sensitive personal information includes race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records and in some cases social security numbers or financial information.  GFORM works to protect the confidentiality and security of such information it obtains in the course of business.  Access to such information is limited and policies and procedures are in place designed to safeguard the information from loss, misuse and improper disclosure.

Your personal data will only be retained to allow us to provide you with a better service in the future.
In accordance with the GDPR, you have the right to obtain a copy of any personal data we hold on you.  If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you are free to notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.

You acknowledge and agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties, for example, in order to conform to any requirements of law or to comply with any legal process.

How do we use the information that you provide to us?
We will retain and process any personal data you supply to us only for the reasons listed below:

• In relation to a service that is relevant and related to your query;
• To respond to any questions or queries that you send to us;
• To obtain feedback on your dealings with our company;
• To provide you with fund updates such as distribution notices; or
• To send you service industry related newsletters and information.

Contacting You
We may contact you for administration reasons related to the service or offer to which you have signed up to.  This includes:

• If you have requested us to via a contact form;
• By signing up to an event or competition;
• To request us to provide you with information about our services, activities or online content;
• To invite you to participate in surveys about our services (participation is always voluntary); or
• Where you have signed up for an online newsletter or ‘ezine’.

Newsletters and updates
You will only receive ezines or similar correspondence and updates from us if you have specifically agreed to it (e.g. newsletter sign up, Facebook page, or via the contact us facility).  It will be made clear to you where you have these choices, by providing opt in tick boxes for you to decide whether you wish to receive ezines.

If you do not wish to be contacted by us in this regard, you can opt out by following the instructions within the ezine – just click unsubscribe and follow the instructions given.  If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

Cookies
Cookies are files which are transferred to your computer by website.  Cookies can store information about your preferences and other information which you need when you visit a website.  They are commonly used on websites.

How we use cookies
We use cookies to monitor our Website traffic, to ensure better service levels and in order to provide you with certain features such as the customised delivery of certain information.  To prevent the use of cookies you should activate the facility which is available in most web browsers that enables a user to deny or accept cookies.

Google Analytics Cookies
These are cookies that are set by this website directly. They are used to collect information about how visitors use our Website.  We use the information to compile reports and to help us improve the Website.  The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.  You can find out more about Google’s position on privacy as regards its analytics service at https://www.google.ie/policies/privacy/ or to opt out please follow this link https://tools.google.com/dlpage/gaoptout

Server analytics
We also collect statistical and analytical information collected through the standard operation of our web servers, providing us with general and not individually specific information.  We will make no attempt to identify individual users, or to associate any technical information collected with any individual user.

Disclaimer
GFORM, its employees, servants and agents, affiliates or other representatives and their respective parent and subsidiary companies, shall not be liable in respect of any claims, emergencies, demands, causes of action, damages, losses, expenses, including without limitation, reasonable legal fees and costs of proceedings arising out of or in connection with the use and/or dissemination of personal information relating to you in accordance with this privacy statement and your consents.

Third Party Sites
You should be aware that where you link to another website from GFORM’s Website, that we have no control over that other website.  We have no responsibility for the privacy practices of other websites.

• Your rights as a Data Subject
• You may request a copy of any personal data we hold on you;
• You may request that we make changes to your data, to ensure that it is accurate and up to date;
• You may get in touch with us at any time to request removal of your data;
• You may, under certain circumstances, object or request restriction of our processing of your data; and
• You may withdraw your consent to our processing of your data at any time.

Exercising your rights, or getting in touch
To exercise your rights, or to get in touch in relation to your data, simply send an email to [email protected] or contact us at +49 (0) 30 555 7929 10 outlining the nature of your request.  We must supply the information to you within one month of receiving the request.  However, this one month period may be extended by two further months where requests are complex or numerous.  We will notify you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Amendments to this statement
We reserve the right in its sole discretion to amend this privacy statement at any time, and you should regularly check this privacy statement for any amendments.