Family Partners
Your Family Office

Privacy Policy

As the controller, FamilyPartners has implemented numerous technical and organizational measures to ensure the most comprehensive protection of personal data processed through this website. However, data transmissions over the Internet can in principle have security gaps, so absolute protection may not be guaranteed. For this reason, each individual is free to transfer personal data to us through other means, such as by phone. The data protection declaration of FamilyPartners is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as for our customers and business partners. For this reason, we would like to first explain the terminology used. In this data protection declaration, we use, among others, the following terms: a) Personal data Personal data refers to any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific factors related to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. b) Data subject The data subject is any identified or identifiable natural person whose personal data is processed by the data controller. c) Processing Processing is any operation or set of operations performed on personal data or sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction. d) Restriction of processing Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future. e) Profiling Profiling refers to any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. f) Pseudonymization Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person. g) Controller or data controller The controller or data controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for their nomination may be provided for by Union or Member State law. h) Processor The processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. i) Recipient The recipient is a natural or legal person, public authority, agency, or other body to which the personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not considered recipients; the processing of such data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. j) Third party A third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller, are authorized to process personal data. k) Consent Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data concerning him or her. The entity responsible for the General Data Protection Regulation (GDPR), other data protection laws applicable in the European Union Member States, and any other provisions related to data protection is: FamilyPartners 111/115 Avenue de Luxembourg L – 4940 Bascharage (Luxembourg) Phone: +352 26 500 891 Email: [email protected] Website: familypartners.eu The FamilyPartners website uses cookies. Cookies are text files stored on a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It is a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables visited websites and servers to differentiate the individual browser from other internet browsers containing different cookies. A specific internet browser can be recognized and identified using the unique cookie ID. Through the use of cookies, FamilyPartners can provide users of this website with more user-friendly services that would not be possible without the cookie setting. With a cookie, information and offers on our website can be optimized for users. Cookies allow us, as mentioned earlier, to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. The website user who uses cookies, for example, does not have to enter access data each time the website is accessed because the website supports it, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie. The data subject can prevent cookies from being set on our website at any time by means of a corresponding setting of the internet browser used and thus permanently deny the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software. This is possible in all popular internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable. The FamilyPartners website collects a range of data and general information when a data subject or an automated system calls up the website. This data and general information are stored in the server log files. The collected data and general information may include (1) the types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (referrer), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our computer systems. When using these general data and information, FamilyPartners does not draw any conclusions about the data subject. This information is rather needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our computer systems and technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, FamilyPartners analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject. On the FamilyPartners website, users have the option to subscribe to the newsletter of our company. The input mask used for this purpose determines what personal data is transmitted, as well as when the newsletter is ordered by the controller. FamilyPartners regularly informs its customers and business partners through a newsletter about company offers. The company’s newsletter can only be received by the data subject if (1) the data subject has a valid email address and (2) they are included in the subscriber register for newsletter dispatch. An email confirmation will be sent to the email address registered by a data subject for the first time for newsletter sending, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove that the owner of the email address as the data subject is authorized to receive the newsletter. When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to the data subject’s computer system at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of a data subject’s email address at a later date and therefore serves the purpose of legal protection for the data controller. The personal data collected as part of a newsletter registration will only be used to send our newsletter. In addition, newsletter subscribers may be informed by email, insofar as this is necessary for the operation of the respective newsletter service or registration, as could be the case in the event of a change to the newsletter offer or a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. Subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for sending the newsletter, can be revoked at any time. For the purpose of revoking consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to inform the controller in a different manner. The FamilyPartners newsletter contains tracking pixels. A tracking pixel is a miniature graphic embedded in these emails, which are sent in HTML format to enable the recording and analysis of log files. This allows for a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, FamilyPartners can see if and when an email was opened by a data subject and which links in the email were clicked by the data subjects. The personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the newsletter dispatch and to even better tailor the content of future newsletters to the interests of the data subject. This personal data will not be transmitted to third parties. Data subjects have the right to revoke the separate declaration of consent issued through the double opt-in procedure at any time. After revocation, this personal data will be deleted by the controller. FamilyPartners automatically considers a withdrawal of the newsletter reception as a revocation. The FamilyPartners website contains information that allows for quick electronic contact with our company, as well as direct communication with us, which also includes a general email address (email). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. This personal data voluntarily provided by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties. Comments made on the FamilyPartners blog can be subscribed to by third parties. In particular, it is possible for a commentator to subscribe to comments following their comments on a particular blog post. If a data subject decides to subscribe to this option, the controller sends an automatic confirmation email to verify the double opt-in procedure to determine whether the owner of the specified email address has opted for this option. The option to subscribe to comments can be terminated at any time. The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage or as long as granted by the European legislator or other applicable legislators. If the purpose of storage is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is systematically blocked or erased in accordance with legal requirements. a) Right to confirmation: Every data subject has the right, as granted by the European legislator, to obtain confirmation from the data controller as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they can contact an employee of the data controller at any time. b) Right of access: Every data subject has the right, as granted by the European legislator, to obtain from the data controller free information about their personal data stored at any time and a copy of this information. In addition, European directives and regulations grant the data subject access to the following information: – The purposes of the processing; – The categories of personal data concerned; – The recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations; – Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; – The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; – The right to lodge a complaint with a supervisory authority; – Where the personal data is not collected from the data subject, any available information as to its source; – The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing. Furthermore, the data subject has the right to obtain information as to whether personal data is transferred to a third country or to an international organization. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they can contact an employee of the data controller at any time. c) Right to rectification: Every data subject has the right, as granted by the European legislator, to obtain from the data controller, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they can contact an employee of the data controller at any time. d) Right to erasure (Right to be forgotten): Every data subject has the right, as granted by the European legislator, to obtain from the data controller the erasure of personal data concerning them without undue delay, and the data controller has the obligation to erase personal data without undue delay where one of the following grounds applies: – The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed. – The data subject withdraws consent on which the processing is based according to Article 6(1)(a) of the GDPR, or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing. – The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR. – The personal data has been unlawfully processed. – The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the data controller is subject. – The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by FamilyPartners, they can contact an employee of the data controller at any time. An employee of FamilyPartners will ensure that the erasure request is complied with without undue delay. Where the data controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the data controller, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of FamilyPartners will arrange the necessary measures in individual cases. e) Right to restriction of processing: Every data subject has the right, as granted by the European legislator, to obtain from the data controller restriction of processing where one of the following applies: – The accuracy of the personal data is contested by the data subject, for a period enabling the data controller to verify the accuracy of the personal data. – The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use. – The data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. – The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the data controller override those of the data subject. If one of the conditions above is met, and a data subject wishes to request the restriction of the processing of personal data stored by FamilyPartners, they can contact an employee of the data controller at any time. The employee of FamilyPartners will arrange the restriction of the processing. f) Right to data portability: Every data subject has the right, as granted by the European legislator, to receive the personal data concerning them, which was provided to a data controller, in a structured, commonly used and machine-readable format. They have the right to transmit those data to another data controller without hindrance from the controller to which the personal data has been provided, where: – The processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and – The processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. To exercise the right to data portability, the data subject can contact an employee of FamilyPartners at any time. g) Right to object: Every data subject has the right, as granted by the European legislator, to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. FamilyPartners will no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If FamilyPartners processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to FamilyPartners processing for direct marketing purposes, FamilyPartners will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by FamilyPartners for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject can contact any employee of FamilyPartners. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications. h) Automated individual decision-making, including profiling: Every data subject has the right, as granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them, or similarly significantly affects them, as long as the decision: – Is not necessary for entering into, or the performance of, a contract between the data subject and a data controller; – Is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or – Is not based on the data subject’s explicit consent. If the decision: – Is necessary for entering into, or the performance of, a contract between the data subject and a data controller, – Is based on the data subject’s explicit consent, FamilyPartners shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, they can contact an employee of FamilyPartners at any time. i) Right to withdraw data protection consent: Every data subject has the right, as granted by the European legislator, to withdraw their consent to the processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw consent, they can contact an employee of FamilyPartners at any time. On this site, the data controller has integrated components from the company AddThis. AddThis is a bookmarking provider. The service allows simplified bookmarking of web pages via buttons. By clicking on the AddThis component with the mouse or by clicking on it, a list of bookmarking and sharing services is displayed. AddThis is used on more than 15 million websites, and the buttons are displayed, according to the operating company’s information, more than 20 billion times per year. On this site, the controller has integrated components from the company Facebook. Facebook is a social network. A social network is a place for social interactions on the Internet, an online community that generally allows users to communicate and interact in a virtual space. A social network can serve as a platform for the exchange of opinions and experiences or allow the online community to provide personal or professional information. Facebook enables social network users to create private profiles, upload photos, and network through friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside the United States or Canada, the data controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With each visit to one of the individual pages of this website, managed by the controller and in which a Facebook component (Facebook plugin) has been integrated, the web browser of the data subject’s computer system is automatically prompted to download the display of the corresponding Facebook component from Facebook via the Facebook component. An overview of all Facebook plugins is available at https://developers.facebook.com/docs/plugins/. During this technical process, Facebook is informed about the specific subpage of our website visited by the data subject. If the data subject is logged into Facebook at the same time, Facebook detects with each visit to our website by the data subject—and for the entire duration of their stay on our website—which specific subpage of our internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, such as the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the data subject’s personal Facebook account and stores the personal data. Facebook always receives information about a visit to our website by the data subject via the Facebook component whenever the data subject is simultaneously logged into Facebook when accessing our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such transmission of information to Facebook is not desired by the data subject, they can prevent it by logging out of their Facebook account before accessing our website. The data protection guideline published by Facebook, available at https://facebook.com/about/privacy/, provides information on the collection, processing, and use of personal data by Facebook. Furthermore, it explains the privacy settings that Facebook offers to protect the data subject’s privacy. Various configuration options are available to allow the data subject to prevent the transmission of data to Facebook. These applications can be used by the data subject to eliminate data transmission to Facebook. On this site, the controller has integrated the Google Analytics component (with the anonymizer function). Google Analytics is a web analytics service. Web analytics involves the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analytics service collects, among other things, data about the website from which a person came (the so-called referrer), the subpages visited, or the frequency and duration of viewing a subpage. Web analytics is primarily used for the optimization of a website and for cost-benefit analysis of internet advertising. On this website, the controller has integrated the Google+ button as a component. Google+ is a social network. A social network is a social meeting place on the Internet, an online community that generally allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or professional information. Google+ allows users of the social network to include the creation of private profiles, upload photos, and establish networks through friend requests. On this website, the controller has integrated Google AdWords. Google AdWords is an internet advertising service that allows advertisers to place ads in Google search engine results and in Google’s advertising network. Google AdWords enables an advertiser to pre-define specific keywords with which an ad will appear only in Google’s search results when a user uses the search engine to retrieve a relevant search result. In Google’s advertising network, ads are displayed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords. The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States. The purpose of Google AdWords is to promote our website by including relevant advertisements on third-party websites and in the search engine results of the Google search engine, and to insert third-party advertising on our website. If a data subject reaches our website through a Google ad, a conversion cookie is placed on the person’s computer through Google. The setting of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, such as the shopping cart of an online shop system, have been called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, i.e., executed or canceled a product sale. The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used to determine the total number of users who have been served through AdWords ads to determine the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject. The conversion cookie stores personal information, such as the web pages visited by the data subject. Each time we visit our internet pages, personal data, including the IP address of the internet access used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical procedure to third parties. The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the internet browser used and thus permanently deny the setting of cookies. Such a setting of the internet browser used would also prevent Google from placing a conversion cookie on the data subject’s computer. In addition, a cookie set by Google AdWords can be deleted at any time via the internet browser or other software. The data subject has the possibility of objecting to interest-based advertising by Google. Therefore, the data subject must access the link www.google.de/settings/ads from each of the browsers they use and make the desired settings. Further information and the applicable data protection provisions of Google can be found at https://www.google.com/intl/fr/policies/privacy/. On this website, the controller has integrated components of the Instagram service. Instagram is a service that can be described as a visual platform, allowing users to share photos and videos, as well as broadcast this data on other social networks. Article 6(1) of the GDPR serves as the legal basis for processing operations for which we obtain consent for specific processing purposes. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as when processing operations are necessary for the provision of goods or any other service, the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the performance of pre-contractual measures, for example, in the case of inquiries regarding our products or services. Our company is subject to a legal obligation whereby the processing of personal data is necessary, such as for the fulfillment of tax obligations; the processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured at our event, and their name, age, health insurance data, or other vital information were to be transmitted to a doctor, hospital, or third party. Then, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations could be based on Article 6(1)(f) of the GDPR. This legal basis is used for processing that is not covered by any of the aforementioned legal grounds if the processing is necessary for the legitimate interests pursued by our company or a third party, unless those interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data. Such processing is particularly allowed as it has been specifically mentioned by the European legislator, who considered that a legitimate interest could be presumed if the data subject is a customer of the data controller (Recital 47, second sentence, of the GDPR). When the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is to conduct our business for the well-being of all our employees. The criteria used to determine the storage period for personal data are the respective legal retention periods. After the expiration of this period, the corresponding data is regularly deleted, as long as it is no longer necessary for the execution of the contract or the initiation of a contract. We specify that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information about the contracting partner). Sometimes, it may be necessary to conclude a contract that the data subject provides us with personal data, which must then be processed by us. The data subject is, for example, obliged to provide us with personal data when our company enters into a contract with them. Non-disclosure of personal data would result in the contract with the data subject not being concluded. Before personal data is provided by the data subject, the data subject must contact an employee. The employee clarifies with the data subject whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide personal data, and the consequences of not providing the personal data. As a responsible company, we do not use automatic decision-making or profiling. This privacy policy has been generated by the privacy policy generator of DGD – your external DPO, which was developed in cooperation with German lawyers from WILDE BEUGER SOLMECKE, Cologne.