Information about the processing of your data
- In the following, websitemeans all of the controller’s pages at https://www.howzatpartners.com;
- personal data means any information relating to an identified or identifiable natural person. A natural person is identifiable if they can be identified, either directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier or to one or more special features that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Personal data is therefore, for example, a person’s name, email address and telephone number, but may also include information about preferences, hobbies and memberships;
- processing means operations or sets of operations carried out with or without the aid of automated procedures in connection with personal data, such as the collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction;
- pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data cannot be attributed to an identified or identifiable natural person;
- consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes in a particular case by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her; and
- Google means Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; reachable in the European Union at: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
Howzat Asset Managers s.á.r.l.
1, rue Jean-Pierre Brasseur
Questions about data protection
If you have any questions about data protection with regard to our company or our website, you can contact us using the above contact details.
We have taken comprehensive technical and organisational precautions to protect your personal data from unauthorised access, abuse, loss and other external disruption. To this end, we regularly review our security measures and adapt them to current standards.
You have the following rights with regard to the personal data concerning you that you can assert against us:
- right of access (Art. 15 GDPR),
- right to rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR),
- right to restriction of processing (Art. 18 GDPR),
- right to object to processing (Art. 21 GDPR),
- right to withdraw your consent (Art. 7(3) GDPR),
- right to receive the data in a structured, commonly used, machine-readable format(‘data portability’) and the right to transfer the data to another controller, if the prerequisites of Art. 20(1) (a) and (b) GDPR are fulfilled (Art. 20 GDPR).
You can assert your rights by informing us using the contact details specified above under ‘Responsible provider’ or by contacting the data protection officer designated by us.
You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data (Art. 77 GDPR).
Use of the website, access data
In principle, you can use our website for purely informational purposes without disclosing your identity. When you access the individual pages of the website in this sense, this only results in access data being transferred to our web hosting service so that the website can be displayed to you. This is the following data:
- browser type/browser version
- operating system used
- language and version of the browser software
- hostname of the accessing device
- IP address
- website from which the request comes
- content of the request (specific page)
- date and time of the server request
- access status/HTTP status code
- referrer URL (website visited before)
- volume of data transferred
- time zone difference from Greenwich Mean Time (GMT)
Temporary processing of the IP address by the system is necessary to make it technically possible to deliver the website to your device. This requires processing of your IP address for the duration of the session. The legal basis for such processing is Art. 6(1) Sentence 1(f) GDPR.
The access data is not used to identify individual users and is not combined with other data sources. The access data is deleted when it is no longer required for achieving the purpose of its processing. In the case of recording the data to provide the website, this is the case when you end your visit to the website.
IP addresses are stored in log files to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context either. In principal, data is deleted after seven days at the latest; further processing is possible in individual cases. In this case, the IP address is deleted or so transformed that an assignment of the retrieving client is no longer possible.
The recording of data for the provision of the website and the processing of data in log files is an absolute necessity for the operation of the website. You may object to the processing. In the event that your objection if justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.
a) Technically necessary cookies
Some elements of our website require that the retrieving browser can be identified even after a page change. This involves processing the following data in the cookies:
- language settings
- items in shopping basket
- login information
The user data collected by technically necessary cookies is not processed to create user profiles.We also use session cookies, which store a session ID that can be used to assign various requests from your browser to the shared session. Session cookies are required for using the website. In particular,they enable us to recognise the device used when you return to the website. If you have an account with us, we use this cookie to recognise you on subsequent visits to the website; otherwise you would have to log in again each time you visited. The legal basis for this processing is Art. 6(1) Sentence 1(f) GDPR. We use session cookies to make using our website more attractive and effective. Session cookies are deleted as soon as you log out or close your browser.
You can object to the processing of your data by cookies. Most browsers are preset to automatically accept cookies. You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.
b) Technically non-essential cookies
- entered search terms
- frequency of page views
- use of website functions
These cookies are used to make using the website more efficient and attractive. The legal basis for this processing is Art. 6(1) Sentence 1(f) GDPR. The technically non-essential cookies are automatically deleted after a specified period, which may vary depending on the cookie.
Where we integrate cookies from third-party providers into our website, we point this out to you separately below.
Contacting our company
When contacting our company, e.g. by email or using the contact form on the website, the personal data provided by you will be processed by us so that we can respond to your enquiry.
In order for us to process enquiries submitted via the contact form on the website, it is essential that youprovidethe region, a name or pseudonym and a valid e-mail address including a confirmation e-mail, your home country, a telephone number and your message to us. At the moment when you submit the message to us, the following data, among others, will also be processed:
- IP address
- date/time of registration
The legal basis for the processing is Art. 6(1)Sentence 1(f) GDPR and Art. 6(1) Sentence 1(b) GDPR, if the contact is made with the intention of concluding a contract and Art. 6 (19 Sentence 1 (a) GDPR based on your consent to process your personal data.
Processing the personal data from the form allows us to process the contact you make with us. Where you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the submission process serves to prevent any misuse of the contact form and to ensure the security of our information technology systems.
The data will not be transmitted to third parties in this context. As soon as processing is no longer necessary, we delete the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.
You have the possibility to object to the processing of your personal data for contact requests at any time. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the previous description of the functions. In such a case, it may not be possible to continue processing the request. In the event that your objection if justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.
Processing and transmission of personal data for contractual purposes
We process your personal data if and to the extent necessary for the initiation, creation, execution and/or termination of a legal transaction with our company. The legal basis for this results fromArt. 6(1) Sentence 1(b) GDPR.
Once the purpose has been achieved (e.g. contract processing), the personal data will be blocked for further processing or erased, unless we are entitled to retain the data for a longer period and process it as required in the respective context on the basis of a consent granted by you (e.g. consent to the processing of your email address for sending promotional emails), a contractual agreement, a statutory authorisation (e.g. authorisation to send direct advertising) or on the basis of justified interests (e.g. retention for asserting claims).
Your personal data will be passed on if
- it is necessary for the creation, execution or termination of legal transactions with our company (e.g. when transmitting data to a payment service provider/a shipping company to process a contract with you) (Art. 6(1) Sentence 1(b) GDPR), or
- a subcontractor or party we use to perform our obligations, which we use exclusively within the framework of providing the offers or services requested by you, needs this data (unless you are expressly informed otherwise, such auxiliary parties are only entitled to process the data insofar as this is necessary for the provision of the offer or service), or
- there is an enforceable official order (Art. 6(1) Sentence 1(c) GDPR) or
- there is an enforceable court order (Art. 6(1) Sentence 1(c) GDPR) or
- we are legally obliged to do so (Art. 6(1) Sentence 1(c) GDPR) or
- the processing is necessary in order to protect the vital interests of the data subject or another natural person (Art. 6(1) Sentence 1(d) GDPR) or
- we are authorised or even obliged to pursue overriding legitimate interests (Art. 6(1) Sentence 1(f) GDPR).
Your personal data will not be transmitted to other persons, companies or bodies unless you have effectively consented to such transmission. The legal basis for the processing is then Art. 6(1) Sentence 1(a) GDPR.
We use external hosting services to provide the following services: Infrastructure and platform services, computing capacity, storage resources and database services, security and technical maintenance services. All data necessary for the operation and use of our website will be processed.
We use external hosting services for the operation of this website. By using external hosting services, we aim to make our website available efficiently and securely. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f) DSGVO.
The collection of data for the provision and use of the website and the processing of data via external web hosts is absolutely essential for the operation of the website. You may object to the processing. In the event of your justified objection, we will examine the situation and either stop or adjust data processing or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.
Google Maps (Google Inc.)
We use Google the Google Maps widget which allows you to view content hosted on external platforms directly from the pages of our website and interact with it. This service might still collect web traffic data for the pages where the service is installed, even when users do not use it.
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Google Maps uses ‘cookies’(see ‘Cookies’ above), which are stored on your device to enable the analysis of how you use the website and Google Maps. The information generated in this way about your use of this website is transferred to and stored by Google on a server in the USA. For the cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the processing by Google Analytics is Art. 6(1) Sentence 1(f) GDPR.We have no knowledge of how long Google stores data and have no way of influencing this.
For more information about the third-party provider Google, please refer to:
Google reCAPTCHA (Google Inc.)
We use Google reCAPTCHA in order to analyse the traffic of our website with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA uses ‘cookies’(see ‘Cookies’ above), which are stored on your device to enable the analysis of how you use the website and Google Maps. The information generated in this way about your use of this website is transferred to and stored by Google on a server in the USA. For the cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the processing by Google Analytics is Art. 6(1) Sentence 1(f) GDPR.We have no knowledge of how long Google stores data and have no way of influencing this.
For more information about the third-party provider Google, please refer to:
Integration of third-party content
The website integrates third-party content such as videos, maps, RSS feeds and graphics from other websites. This integration always requires that the providers of this content (“third-party providers”) perceive the IP addresses of users. This is because without the IP address they would not be able to send the content to the browser of the respective user. As such, the IP address is required to display this content.
We endeavour to only use content from third-party providers who process the IP address solely for delivering the content. We do however have no influence over whether the third-party providers process the IP addresses, e.g. for statistical purposes. If we are aware of such activity, we inform you of this in the following.
Some of the third parties may process data outside the European Union.