PRIVACY NOTICE

Information on data processing in accordance with Art 13 and 14 of the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 for the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereafter “GDPR”).

1. CONTROLLER

The controller within the meaning of Art 4(4) GDPR for the website www.iqam.com and the services offered on said website is Spängler IQAM Invest GmbH, Franz-Josef-Strasse 22, 5020 Salzburg (hereafter “Spängler IQAM Invest”). If you have any questions, you can contact Spängler IQAM Invest by:

  • email: datenschutz@iqam.com
  • telephone: +43 505 8686-0
  • fax: +43 8686-869
  • post: Spängler IQAM Invest, Data Protection, Franz-Josef-Strasse 22, 5020 Salzburg

2. PROCESSING OF PERSONAL DATA:

2.1. GENERAL

You share personal data with us in the context of our business relationship. If necessary for the provision of our services or for compliance with statutory and regulatory obligations, we process these data together with personal data obtained from publicly available sources or legitimately passed on to us by third parties. We process data such as personal data, identification data, authentication data, order data, data we collect for the purpose of fulfilling contractual or statutory and regulatory obligations and, if applicable, data about your financial situation and data we receive in connection with your use of our information and event offers.

We process the personal data in accordance with the data protection regulations. The legal basis for the processing is the necessity for the performance of a contract or in order to take steps prior to entering into a contract (Art 6(1)(b) GDPR) or for compliance with a legal obligation to which we are subject (Art 6(1)(c) GDPR). In addition, the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, e.g. to protect employees and customers, to grow our company, products and services, to win customers back, to prevent or combat fraud, to enforce or defend against legal claims (Art 6(1)(f) GDPR). If you have given us your consent, your personal data is processed for the aforementioned purposes (Art 6(1)(a) GDPR). You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Consent may be withdrawn by sending an email to datenschutz@iqam.com.

2.2. WEBSITE

When you visit our website, data is stored on our servers for security purposes (e.g. IP address, access time, the pages visited). We process these data for data security reasons and to ensure the stability and reliability of our system.

2.2.1. COOKIES

Our website uses so-called “cookies”. These small text files are stored on your computer and used to analyse your use of our website. You may refuse the use of cookies by selecting the appropriate settings in your browser; however, please note that if you do this you may not be able to use the full functionality of this website.

2.2.2. GOOGLE ANALYTICS:

Our website uses Google Analytics, a web analysis service provided by Google Inc. (hereafter “Google”). Google Analytics uses so-called “cookies”, which are text files stored on your computer, to help the website analyse how you use the site. The information generated by the cookie about your use of this website is transmitted to and stored by Google on a server in the United States. We use Google Analytics with active IP anonymisation.  This means that Google shortens the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area.  Only in exceptional cases is the IP address transmitted to a Google server in the US and shortened there.  Google uses this information on our behalf to analyse your use of the website, to compile reports on website activity and to provide other services relating to website use and Internet use via the website operators. Google does not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings in your browser; however, please note that if you do this you may not be able to use the full functionality of this website.  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 downloading and installing the opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout?hl=en.

You can prevent Google Analytics from collecting data by clicking on the following link. An opt-out cookie is installed that prevents your data from being collected by Google Analytics when you visit this website: Google Analytics Opt-out. Please note that you need to click this link again when you have deleted all the cookies in your browser.

For more information on Google’s terms of service and its privacy policy, please visit http://www.google.com/analytics/terms/us.html and https://policies.google.com/?hl=en.

2.2.3. FUND PRICE SUBSCRIPTION:

In order to be able to keep you up to date on the prices of your Spängler IQAM Invest fund in the selected frequency, we require your registration on our website. After you have entered your details, you will receive an email confirming your subscription. When you register for the fund price subscription, the following personal data are processed: gender (title), name, email address, selected funds, selected frequency, login data.

The legal basis for the processing is your consent (Art 6(1)(a) GDPR). You give your consent by clicking on the check box together with the reference to the privacy notice and the button “Set up subscription”.

You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Consent can be withdrawn by sending an email to datenschutz@iqam.com or by using the unsubscribe link included in each fund price information.

2.2.4. CUSTOMER LOGIN:

In order to receive product-specific information, in particular fund prices for customers of special funds, customers are given password-protected access to an individual customer area. The following personal data are processed in this connection: Gender (title); name and other personal information; company data; email address; account and login data; associated funds; if applicable, selected funds in watchlist; fund documents, if applicable, protocols and other customer information.

The existence of a contractual relationship serves as the legal basis for processing (Art 6(1)(b) GDPR)

2.3. INFO MAILING

For marketing and advertising purposes, especially for info mailings, Spängler IQAM Invest processes personal data of customers, contact persons of customers, interested parties. The following personal data my be processed in this connection: Gender (title), names and other personal data (e.g. contact data, address, date of birth), documentation data (e.g. correspondence and reports), contract and transaction data, advertising and sales data, image and sound data (e.g. telephone recordings), data for the fulfilment of statutory and regulatory requirements and data that we receive in connection with your use of our information and event offers and, if provided by you, information about your interests.

Insofar as third party services are used for the implementation of marketing and advertising measures, data will only be passed on to the extent necessary for the marketing and advertising measure.

The legal basis for the processing is either your consent (Art 6(1)(a) GDPR) or, if you already have a customer relationship with Spängler IQAM Invest, a legitimate interest (Art 6(1)(f) GDPR).

You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Consent can be withdrawn by sending an email to datenschutz@iqam.com or by using the unsubscribe link included in each message.

If a legitimate interest of Spängler IQAM Invest provides the legal basis for processing, you can object to the data processing at any time. Consent can be withdrawn by sending an email to datenschutz@iqam.com or by using the unsubscribe link included in each message.

2.4. JOB APPLICATIONS

Spängler IQAM Invest processes the data voluntarily submitted by job applicants for the purpose of processing applications and for the selection procedure.

The legal basis for the processing is the applicant’s consent (Art 6(1)(a) GDPR). Each job advertisement points out that, by submitting a job application, the applicant consents to data processing for the aforementioned purposes. Accordingly, the submission of the application constitutes consent.

The applicant may withdraw his/her consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Consent can be withdrawn by sending an email to datenschutz@iqam.com.

3. RECIPIENTS OF PERSONAL DATA / PROCESSORS:

Spängler IQAM Invest ensures that personal data are processed only by those internal departments and employees who need them to fulfil their tasks and obligations. Data are only passed on to third parties if this is necessary. Recipients of personal data can be, in particular, event partners, partners in connection with marketing activities, shipping partners, partners in the field of technical infrastructure and applications, partners in the area of data and document destruction, etc.

We contractually oblige all processors to process personal data only within the scope of fulfilling their respective service and to implement appropriate technical and organisational measures.

Personal data may also be passed on to public bodies and institutions (e.g. financial market authority, tax authorities, etc.), if this is required to fulfil statutory obligations.

The processing of personal data may also be carried out by companies based in a third country. In this case, it cannot always be ruled out that data may undergo processing in a third country. However, we ensure that the data are subject to an appropriate level of data protection and that the provisions of Art 44 et seqq GDPR are complied with.

4. DATA SECURITY

We take technical and organisational precautions to ensure that our website and other systems are protected against loss, destruction, access, modification and dissemination of your data by unauthorised third parties.

Despite making every effort to maintain a consistently high level of due care, it cannot be fully ruled out that information you share with us via the Internet may be viewed and used by others.

Please note that we therefore accept no liability whatsoever for the disclosure of information resulting from data transmission errors not caused by us and/or unauthorised access by third parties (e.g. hacking of email accounts or telephone, interception of faxes).

5. RETENTION PERIOD

We store personal data for the duration of a business relationship or consent given. In addition, we store personal data for as long as there are statutory retention and documentation obligations or statutory periods of limitation. We also store personal data as long as they are required in connection with the defence against or enforcement of any legal and liability claims. The pertinent legal regulations can be found in the Austrian Companies Act, the Federal Fiscal Code, the Investment Funds Act, the Alternative Investment Fund Managers Act, the Banking Act, the Financial Market Money Laundering Act and the Civil Code.

6. YOUR RIGHTS AS A DATA SUBJECT

As a person affected by the processing of personal data, you have the following rights:

  • Right of access pursuant to Art 15 GDPR:

You have the right to request a copy of the personal data undergoing processing. If applicable, you have the right to obtain information about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient of the personal data, the retention period, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the existence of a right to lodge a complaint with a supervisory authority, as well as all available information about the source of data not provided by you.

  • Right to rectification pursuant to Art 16 GDPR:

You have the right to obtain the rectification of inaccurate personal data concerning you without undue delay.

  • Right to erasure (“right to be forgotten”) pursuant to Art 17 GDPR:

You have the right to obtain the erasure of personal data concerning you without undue delay.

  • Right to restriction of processing pursuant to Art 18 GDPR:

You have the right to obtain restriction of processing under certain conditions (e.g. if the accuracy of the personal data is contested, if the processing is unlawful, if the controller no longer needs the personal data for the purposes of the processing, etc).

  • Right to data portability pursuant to art 20 GDPR:

You have the right to receive the personal data concerning you, which you have provided, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

  • Right to object pursuant to Art 21 GDPR:

You have the right to object, under certain conditions, to the processing of personal data concerning you.

All abovementioned rights of data subjects are to be exercised vis-à-vis Spängler IQAM Invest. Please refer to the contact options stated in Section 1.

In addition, you have the right to appeal to the Austrian Data Protection Authority (Datenschutzbehörde) in connection with the processing of your personal data.

7. QUESTIONS ABOUT DATA PROTECTION

If you have any questions about data protection at Spängler IQAM invest, please send an email to datenschutz@iqam.com.