Data Privacy Policy
(Last updated: 25 May 2018)
Thank you for visiting our website and for your interest in our company. The protection of your personal data is a matter of great importance to us. Below we inform you according to art. 12, 13 and 21 of the General Data Protection Regulation (GDPR) about the handling of your personal data when visiting our website capnamic.com.
Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes information such as the civil name, address, telephone number and date of birth.
I. Responsible
Body
Responsible Body according to GDPR
Capnamic Ventures Management GmbH
Kaiser-Wilhelm-Ring 17-21
50672 Cologne
Germany
Email: info@capnamic.com
Phone: +49 (0)2216 77 81 93-0
Fax: +49 (0)221 6 77 81 93-1
II. Data Protection Officer
Contact details of our data protection officer:
Capnamic Data protection officer
Kaiser-Wilhelm-Ring 17-21
50672 Köln
Email: privacy@capnamic.com
Fax: +49 (0)221 6 77 81 93-1
III. Purposes and Legal Basis
of the Data Processing
1. Informational Use of the Website
You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. do not not access the data room, place an order or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website as well as information that is transmitted to us through cookies used for statistical analysis of the use of our website.
a. Technical Provision of the Website
You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. do not not access the data room, place an order or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website as well as information that is transmitted to us through cookies used for statistical analysis of the use of our website.
You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. do not not access the data room, place an order or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website as well as information that is transmitted to us through cookies used for statistical analysis of the use of our website.
- IP-adresse
- Browser type / -version (e.g.: Firefox 59.0.2 (64 Bit));
- Browser language (e.g.: German);
- Operating system (e.g.: Windows 10);
- Internal resolution of the browser window;
- Screen resolution;
- Javascript activation;
- Java on / off;
- Cookies on / off;
- Color depth;
- Time of access.
Your information, collected by us through the aforementioned cookies, will not be used by us to create user profiles or to evaluate your browsing behavior. We process your personal data for the technical provision of our website on the following legal basis:
- for the fulfilment of a contract or for the implementation of pre-contractual measures pursuant to art. 6 para. 1 letter b GDPR, provided you visit our website to obtain information about our products and our events; and
- to protect our legitimate interests pursuant to art. 6 para. 1 letter f GDPR in order to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website.
b. Statistical Analysis of Website Usage and Range Increase
For the purpose of statistical analysis of the use of our website, we use Google Analytics and thus cookies, which enable an analysis of your browsing behavior. This enables us to improve the quality of our website and its content. We learn how the website is used and can thus continuously optimize our offer. The information obtained in the context of the statistical analysis of our website will not be merged with your other data collected in the context of the website. We process your personal data for statistical analysis of the use of our website on the following legal basis:
- on the basis of your consent pursuant to art. 6. para. 1 letter a GDPR.
Google Analytics
On our website we use Google Analytics, a web analysis service of Google Inc. Google Analytics uses so-called “cookies”: text files placed on your computer, enabling an analysis of the use of the website by you. The information generated by the cookie about your use of our website is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on our website, Google will shorten your IP address within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide the website operator with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
On our website we use Google Analytics with the extension “_anonymizeIp()”. This arranges for IP addresses to be further processed in abridged form, a direct relation to a person can be ruled out.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that in this case you may not be able to use the full scope of functions on our website.
You can prevent the collection of data generated by the cookie and relating to your use of our website (including your IP address) and the transmission to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser plugin, you can click this link to prevent Google Analytics from collecting data about our website in the future. An opt-out cookie is stored on your device. If you delete your cookies, you must click the link again.
For more information on Google Analytics’ Terms of Use and Privacy Policy, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/
2. Active Use of the Website
In addition to the merely informational use of our website, you can also actively use it to present an investment opportunity to us, to register for an event, to register for our newsletter or to contact us. When presenting an investment opportunity to us, you will be asked to fill out a Typeform to provide us with information necessary to handle your inquiry. The data provided to us in this form will be only used to process your inquiry. In addition to the above-mentioned processing of your personal data for merely informational purposes, we will also process other personal data that we require from you to process and respond to your inquiry.
a. User Requests
In order to process and answer your inquiries to us via our e-mail address, we process your personal data provided by you in this context. In any case, this includes your name and e-mail address in order to send you an answer, as well as the other information that you send us in the context of your message.
We process your personal data in order to respond to user inquiries on the following legal basis:
- to protect our legitimate interests pursuant to art. 6 para. 1 lit f GDPR; our legitimate interest is to answer customer inquiries appropriately.
b. LP Login
We use a data room service by Intra Links, Inc., 150 East 42nd Street, 8th Floor, New York, NY 10017 (www.intralinks.com) in order to provide you – if you are a Capnamic Limited Partner – with the option of viewing certain documents.
The access to this data room is only granted to those Limited Partners who have received a corresponding access code from us.
We process your data for the above purposes on the following legal basis:
- for the performance of a contract or for the implementation of pre-contractual measures pursuant to art. 6 para. 1 letter b GDPR, to grant you access to the data room; and
- to safeguard our legitimate interests pursuant to art. 6 para. 1 letter f GDPR, in order to make the portal technically available to you. Our legitimate interest is to be able to provide you with an appealing, technically functioning and user-friendly portal.
c. Transmissions of Newsletters
With your consent, we use your data for advertising purposes, i.e. the transmission of our newsletter. We collect mandatory information such as your e-mail address. You can cancel the newsletter at any time by clicking on the unsubscribe link provided in the newsletter.
We process your data for the dispatch of newsletters on the following legal basis:
- If you have given us your consent by double opt-in procedure, pursuant to art. 6 para. 1 letter a GDPR.
IV. Links
Some sections of our web pages contain links to the web pages of third parties. These websites are subject to their own data protection principles. We are not responsible for their operation including the data handling. If you send information to or about such third party sites, you should review the privacy statements of those sites before you submit any information that may assigned to you.
V. Categories of Recipients
Firstly, only our employees will be informed of your personal data. In addition, we share your personal data with other recipients who provide services to us in connection with our website, insofar as this is legally permitted or prescribed. We limit the transfer of your personal data to what is necessary, in particular to be able to complete your order. In some cases, our service providers receive your personal data as contract data processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently with your data, which we transmit to them.
Below, we describe the categories of recipients of your personal data:
- IT service providers who administrate and host our website,
- IT service providers to provide additional functionalities and services on our website.
VI. Transfer into Third countries
As part of the use of Intralinks we transfer personal data to the USA. As part of the use of Google Analytics we transfer your shortened IP address to the USA. The data transfer is based on the EU Commission implementing decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EG of the European Parliament and of the Council on the adequacy of the protection provided by the EU-US data privacy shield.
Furthermore, we do not transfer your personal data to countries outside the EU or the EEA or to international organisations.
VII. Duration of Storage
1. Informational Use of the Website
When using our website for information purposes only, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our website, your personal data will be deleted immediately.
This does not apply to the log files, which will be deleted after 60 days but are only saved in anonymized form. Google Analytics cookies remain stored for the duration of up to two years. You have the option to delete installed cookies yourself at any time.
2. Active Use of the Website
If you actively use our website, we initially store your personal data for the duration of responding to your inquiry or for the duration of your subscription to our newsletter. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract. In addition, we will store your personal data until any legal claims arising from the relationship with you become time-barred, in order to use them as evidence if necessary. The limitation period is generally between 12 and 36 months, but can also be up to 30 years. Upon expiry of the limitation period, we delete your personal data, unless there is a legal obligation to store such data, for example from the German Commercial Code (sec.238, 257 para. 4 HGB) or from the Tax Code (sec. 147 para. 3, 4 AO). These retention obligations can last from two to ten years.
VIII. Your Rights as Data Subject
Under the legal provisions you are entitled to the following rights as data subject, which you can assert against us:
Right to information:You are entitled to request confirmation from us at any time within the scope of art. 15 GDPR as to whether we are processing personal data relating to you; If this is the case, you are also entitled under art. 15 GDPR to receive information about such personal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.
Right to correction: According to art. 16 GDPR, you are entitled to demand correction of the personal data stored about you if it is inaccurate or incorrect.
Right to deletion: You are entitled, under the conditions of art. 17 GDPR, to request from us the deletion of personal data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.
Right to limitation of processing: Under the conditions of art. 18 GDPR you are entitled to request from us the limitation of the processing of your personal data.
Right to data transferability: You are entitled, under the conditions of art. 20 GDPR, to request from us the provision to you of the personal data relating to you that you have submitted to us in a structured, current and machine-readable format.
Right of revocation: You have the right to revoke your consent to the processing of personal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.
Right to objection: You are entitled to object to the processing of your personal data under the conditions of art.21 GDPR, meaning that we have to terminate the processing of your personal data. The right of objection exists only within the limits provided for in art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.
Right of appeal to a supervisory authority: You are entitled to file a complaint with a supervisory authority, inparticular in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of personal data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy. The supervisory authority responsible for us is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestr. 2-4
40213 Dusseldorf
Phone: 0211/38424-0
Fax:0211/38424-10
Email: poststelle@ldi.nrw.de
However, we recommend that you always address a complaint to our data protection officer first.
If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our data protection officer.
IX. Scope of your Obligations to provide Data
Generally, you are not obliged to provide us with your personal data. However, if you do not provide this information, we will not be able to make our website available to you, answer your questions and enter into a contract with you. Personal data which we do not necessarily require for the above-mentioned processing purposes are marked as voluntary information by a ” if applicable ” or another symbol.
X. Automated Decision Making/ Profiling
We do not use automated decision making or profiling (an automated analysis of your personal circumstances).
Information about your right to object pursuant to art. 21 GDPR
You have the right to object at any time to the processing of your data on the basis of art. 6 para. 1 f GDPR (data processing on the basis of a balance of interests) or art. 6 para. 1 e GDPR (data processing in the public interest), if there are reasons for this arising from your particular situation. This also applies to profiling based on this provision within the meaning of art. 4 No. 4 GDPR.
If you object, we will no longer process your personal data, unless we can prove compelling and applicable reasons for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
The objection can be made without formality and should be addressed to
Capnamic Ventures Management GmbH
Kaiser-Wilhelm-Ring 26
50672 Cologne
Germany
Email: info@capnamic.com
Tel no: +49 (0)2216 77 81 93-0
Fax no: +49 (0)221 6 77 81 93-1
XI. Amendments
We reserve the right to change this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on our website. Unless otherwise specified, such amendments shall take immediate effect. Please check this privacy policy regularly to ensure you have the latest version.
Last updated in May 2018