Privacy Policy for W & S Portfoliomanagement GmbH

W & S Portfoliomanagement GmbH highly values the protection of your personal data. This privacy policy informs you about how we collect, process, and use your personal data when you interact with our online platform and avail yourself of our portfolio management and investment advisory services. We adhere strictly to the provisions of data protection law, particularly the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

1. Name and Contact Details of the Controller

The controller for data processing on this website is:

W & S Portfoliomanagement GmbH

Hafengasse 18

89073 Ulm

2. Collection and Processing of Personal Data

We collect personal data only to the extent necessary for the provision of our services and the functionality of our online platform. This may include:

• Contact Information: When you use our contact form, we collect your name, email address, and any other information you voluntarily provide in your message. This data is used solely to respond to your inquiry.
• Usage Data: When you visit our online platform, our servers automatically record certain information, including your IP address, browser type and version, operating system, referrer URL, pages visited, and the time and date of your visit. This data is collected for technical purposes and to improve the stability and security of our online platform.
• Data for Services: If you become a client, we will collect further personal and financial data necessary for providing portfolio management and investment advisory services (BaFin-ID: 10149116). This data is detailed in separate agreements and consent forms.

3. Legal Basis for Processing

The processing of your personal data is based on the following legal grounds:

• Consent (Art. 6 Abs. 1 lit. a GDPR): If you have given us explicit consent for the processing of specific personal data (e.g., via our contact form). You can withdraw your consent at any time.
• Performance of a Contract (Art. 6 Abs. 1 lit. b GDPR): When processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (e.g., providing investment advice).
• Legal Obligation (Art. 6 Abs. 1 lit. c GDPR): If processing is necessary for compliance with a legal obligation to which we are subject (e.g., regulatory requirements under financial law).
• Legitimate Interests (Art. 6 Abs. 1 lit. f GDPR): Where processing is necessary for the purposes of the legitimate interests pursued by W & S Portfoliomanagement GmbH or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject (e.g., for system security and optimization of our online platform).

4. Data Security

We implement comprehensive technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security measures are continuously improved in line with technological developments. Data transmission via our online platform (e.g., via the contact form) is encrypted using SSL/TLS technology.

5. Your Rights as a Data Subject

Under the GDPR, you have the following rights regarding your personal data:

• Right of Access (Art. 15 GDPR): You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information.
• Right to Rectification (Art. 16 GDPR): You have the right to demand the rectification of inaccurate personal data concerning you.
• Right to Erasure (Art. 17 GDPR): You have the right to obtain the erasure of personal data concerning you under certain conditions.
• Right to Restriction of Processing (Art. 18 GDPR): You have the right to obtain restriction of processing under certain conditions.
• Right to Data Portability (Art. 20 GDPR): You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format.
• Right to Object (Art. 21 GDPR): You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.
• Right to Lodge a Complaint (Art. 77 GDPR): Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The supervisory authority responsible for W & S Portfoliomanagement GmbH is the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg.

6. Cookies

Our online platform may use cookies to enhance the user experience and ensure the technical functionality of the site. Cookies are small text files that are stored on your device by your browser. They do not cause any harm to your device and do not contain viruses. Most of the cookies we use are "session cookies," which are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser on your next visit. You can configure your browser to inform you about the setting of cookies, to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when closing the browser. Deactivating cookies may limit the functionality of our online platform.

7. Data Retention

We retain your personal data only as long as necessary for the fulfillment of the purposes for which it was collected, or as required by legal obligations (e.g., commercial and tax law retention periods). Once these purposes are fulfilled or the legal retention periods expire, your data will be securely deleted.

8. Changes to this Privacy Policy

We reserve the right to adapt this privacy policy from time to time to comply with current legal requirements or to reflect changes in our services. The updated privacy policy will be published on our online platform, and the date of the last update will be indicated. We encourage you to review this policy periodically to stay informed about how we are protecting your information.