Data protection is of a particularly high priority for the management of the Bullfinch Asset Aktiengesellschaft (hereinafter "we", "us", "our", or "Bullfinch"). We will process personal data in accordance with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Bullfinch. Personal data means any information relating to an identified or identifiable individual, as defined in Art. 4 GDPR, e.g. name, address, email address or telephone number. By means of this Privacy Policy, Bullfinch would like to inform you of the nature, scope, and purpose of its collection and processing of personal data. Furthermore we explain to you your rights as data subjects.
1. Name and contact details of the controller and contact details of the data protection officer
Controller for the purposes of GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Bullfinch Asset Aktiengesellschaft
Opernplatz 14
60313 Frankfurt am Main
Germany
You can reach the data protection officer under the following address: dpo@bullfinch.com
2. Collection of personal data when visiting the website
The website of Bullfinch collects a series of personal data when you call up the website. The personal data is stored in the server log files. The server log files contain the following information which constitutes personal data because the IP address is collected and thereby the information is related to you:
- the browser types and versions used,
- the operating system used by the accessing system,
- the website from which an accessing system reaches Bullfinch's website (so-called referrers),
- the sub-websites,
- the date and time of access to the Internet site,
- an Internet protocol address (IP address),
- the Internet service provider of the accessing system, and
- any other similar data and information that may be used in the event of attacks on Bullfinch's information technology systems.
When using this personal data, Bullfinch does not draw any conclusions about you. The legal basis for this collection and processing of personal data is Bullfinch's legitimate interest in delivering the content of its website correctly, Art. 6 par. 1 (1) lit. f GDPR. In addition, Bullfinch requires this personal data to optimize the content of its website as well as its advertisement. In this case, the legal basis for the data processing is your consent, Art. 6 par. 1 (1) lit. a GDPR. Where Bullfinch needs this personal data to provide law enforcement authorities with the information necessary for criminal prosecution in case of cyber-attack, the legal basis is Art. 6 par. 1 (1) lit. c GDPR. Additionally, Bullfinch analyzes pseudonymously collected data and information statistically, with the aim of increasing the data protection and data security of Bullfinch enterprise, and to ensure an optimal level of protection for the personal data Bullfinch processes. The pseudonymized data of the server log files are stored separately from all personal data provided by you.
3. Registration on the Bullfinch Website
You have the possibility to register on the website with personal data. If you choose to register on the website by filling in the form, whether as an investor or a clean tech company, Bullfinch processes the following personal data:
- Name,
- The company you work for,
- Phone number and
- Email address
- Password
The personal data entered by the user is collected and stored exclusively for internal use by Bullfinch, and for Bullfinch's own purposes.
By registering on the website of Bullfinch, the IP address — assigned by the Internet service provider (ISP) and used by you —, date, and time of the registration are also stored. This personal data is stored to prevent the misuse of Bullfinch's services, and, if necessary, to enable investigations of committed offenses. Insofar, the storage of this data is necessary to safeguard Bullfinch's legal interests, and the legal basis for such collection and processing is Art. 6 par. 1 (1) lit. f GDPR.
The personal data is not transferred to third parties unless there is a statutory obligation to do so, or if the transfer serves the aim of criminal prosecution. In this case, the legal basis for the data processing is Art. 6 par. 1 (1) lit. c GDPR.
Bullfinch processes your personal data collected through the registration so Bullfinch can offer you content or services that may only be offered to registered users due to the nature of the matter in question. Registered users are free to change the personal data specified during the registration at any time, or to have it completely deleted from the data stock of Bullfinch. Bullfinch processes the personal data in order to present to you the available portfolios of your assets and investments, if you register as an investor. If you register as a clean tech company Bullfinch processes your data in order for you to become a partner of Bullfinch and to provide to you information about tailor made project financing for your business. The legal basis for this personal data processing is your consent Art. 6 par. 1 (1) lit. a GDPR.
- Registration through LinkedIn
If you register on Bullfinch's website with your LinkedIn profile, you will be re-directed from this website to the website of LinkedIn. LinkedIn will then ask you to enter your log-in credentials.
When you enter your log-in credentials for your LinkedIn profile, Bullfinch receives the following data from LinkedIn:
- Name
- Photograph
- Primary email address associated with your LinkedIn account,
The data received from LinkedIn will be used to complete your Bullfinch registration. You can unlink your LinkedIn account at any time. The legal basis for the data processing is Art. 6 par. 1 (1) lit. a GDPR.
4. Contact option via the website
For questions of any kind, Bullfinch offers you the opportunity to contact Bullfinch by e-mail. In doing so, it is necessary to provide a valid e-mail address, first and last name and the company name, so that Bullfinch knows from whom the request originates and to be able to answer it. Further information can be provided voluntarily. To process your request, the legal basis for the data processing is Art. 6 par. 1 (1) lit. b or lit. f GDPR. In case your query is contract-related, the provision of your personal data is a contractual requirement. In case your query is not contract-related, Bullfinch's legitimate interest in processing your personal information is to communicate with you.
5. Who bullfinch shares personal data with
Bullfinch discloses your personal data to the following categories of recipients:
- to Bullfinch's group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help enhance the security of this Website), or who otherwise process personal data for purposes that are described in this Privacy Policy.
- to any competent law enforcement body, regulatory or government agency, court or other third party where Bullfinch believes disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to any other person with your consent to the disclosure.
6. Cookies
The website of Bullfinch uses cookies. Cookies are text files that are stored in 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 of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, Bullfinch can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on this website can be optimized with the user in mind. Cookies allow us to recognize website users. The purpose of this recognition is to make it easier for users to utilize this website. As an example, a website user who allows cookies does not have to enter access data each time the website is accessed.
- Bullfinch uses the following necessary cookies:
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies and the user has no choice whether it wants to allow these cookies or not, they are not optional. The legal basis for this collection and processing of your personal data is Bullfinch's legitimate interest in ensuring proper functioning of its website, Art. 6 par. 1 (1) lit. f GDPR.
Name: Cookie Consent
Provider: Cookiebot
Purpose: Stores the user's cookie consent state for the current domain.
- Bullfinch uses the following preference cookie:
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region where you are located.
Name: _ga
Provider: Google Tag Manager
Purpose: Register a unique ID that is used to generate statistical data on how the visitors uses the website.
- Bullfinch uses the following statistic cookies:
Statistic cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.
_ga_#
Google Tag Manager
Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit.
_gat
Google
Used by Google Analytics to throttle request rates
_gid
Google
Registers a unique ID that is used to generate statistical data on how the visitor uses the website
Locale
Personio
The cookie determines the preferred language and country-setting of the visitor – This allows the website to show content most relevant to that region and language.
Insofar as the other aforementioned cookies collect and process personal data, the legal basis is your consent, Art. 6 par. 1 (1) lit. a GDPR.
In addition to making your choices through our cookie menu (available here), you may, at any time, prevent the setting of cookies through this website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you completely deactivate the setting of cookies through your browser, not all functions of this website may be entirely usable.
7. Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, Bullfinch has integrated Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
For the web analytics through Google Analytics Bullfinch uses the application "_gat. _anonymizeIp". By means of this application, the IP address of your Internet connection is abridged by Google and anonymised when accessing this websites from a Member State of the European Union or the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on this website. Google uses the collected data and information, inter alia, to evaluate the use of this website and to provide online reports, which show the activities on this website, and to provide other services concerning the use of this website for Bullfinch.
Google Analytics places a cookie on your IT system . The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of the website. With each call-up to one of the individual pages of this website, which is operated by Bullfinch and into which a Google Analytics component was integrated, your Internet browser will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, Google obtains certain personal data such as your IP address, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as your language settings and IP address, your operating system and service provider, the location from which the access was made, the access time, the frequency of visits of Bullfinch's website by you and your behaviour flow (subpages visited). If you are accessing from a mobile device the operating system, the service provider and screen resolution will be processed as well.
Insofar as the collected data are personal data, Bullfinch's legal basis of processing your personal data is your consent, Art. 6 par. 1 (1) lit. a GDPR.
With each visit to Bullfinch's website, such personal data, including the IP address of your Internet access, will be transmitted to and stored by Google in the United States of America. Google may transfer this personal data to third parties.
You may, as stated above, prevent the setting of cookies through this website at any time by setting your choices in our cookie menu, and by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on your IT system. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, you have the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude this. For this purpose, you must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If your IT system is later deleted, formatted, or newly installed, then you must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by you or any other person who is attributable to your sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
8. Social Plugins
Bullfinch uses plugins for the social network LinkedIn on this website, which leads Bullfinch to profiles of this social network. The legal basis for the data processing is Art. 6 par. 1 (1) lit. a GDPR.
Bullfinch has no control over the collection or further processing of personal data in connection with your use of the Bullfinch website, which may be carried out by LinkedIn as a third party through your use of their login function. Bullfinch therefore strongly recommends that you read their privacy policy, terms of use and privacy controls. With this in mind:
You can view LinkedIn's Privacy Policy and Terms of Use by clicking on the links provided.
In this regard, you should be aware that Bullfinch has no control over, and accepts no responsibility or liability for, the privacy policy and use of personal data by parties other than us. This also applies to users of Bullfinch's website, the operators of websites to which this website links, or third-party service providers to whom you provide your personal data directly. Bullfinch therefore strongly recommends that you also read the privacy policies, terms of use and privacy controls of these companies.
9. Your data subject rights
You have the right:
- To revoke your consent once given to us at any time. This has the consequence that Bullfinch may no longer continue the data processing based on this consent for the future. However, this will not affect the processing of your personal data in the past.
- To request information about your personal data processed by Bullfinch (Art. 15 GDPR). In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details, as well as the significance and the envisaged consequences of such processing for you;
- To request correction, without undue delay of incorrect or the completion of your personal data stored by us (Art. 16 GDPR);
- To request erasure of your personal data stored by us (Art. 17 GDPR), unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;
- To request restriction of the processing of your personal data (Art. 18 GDPR), insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure, we no longer need the data, but you need it for the assertion, exercise or defense of legal claims or you have objected to the processing;
- To receive your personal data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller (Art. 20 GDPR);
- If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 par. 1 (1) lit. f GDPR, you may object to the processing of your personal data (Art. 21 GDPR), provided that there are grounds for doing so that arise from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation. If you wish to exercise your right of objection, an e-mail to dpo@bullfinch.com will suffice.
- To complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or Bullfinch's company headquarters for this purpose.
10. Data protection for job applications and the application procedures
You have the possibility to apply for job vacancies on the Bullfinch website. When you apply for a vacancy at Bullfinch, Bullfinch will collect and process your personal data for the purpose of the application procedure. Personal data Bullfinch processes for your application include:
- Name,
- E-Mail,
- Telephone number,
- Expected salary,
- Your CV,
- Details of your qualifications, skills, experience and employment history and
- Any other information in your application you choose to share with us (e.g. hobbies).
For this reason, please consider whether there is any personal data, such as health information, information on family relations or similar, that is not necessary for Bullfinch's recruitment process.
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the Human Resources department, department managers and recruitment team and interviewers involved in the recruitment process. Bullfinch may also share parts of your personal data when Bullfinch gets in contact with references you mention in your application, to help Bullfinch evaluate and confirm your qualifications for employment opportunities at Bullfinch.
The legal basis of the data processing is Art. 88 par. 1 GDPR in connection with Sec. 26 par. 1 (2) var. 1 BDSG.
11. Data retention
Bullfinch processes your personal data only for the period necessary to achieve the purpose of the processing, or as far as this is granted by the European legislator or other legislators in laws or regulations to which Bullfinch is subject to.
If the purpose for which the data had been collected and subsequently processed is not applicable anymore, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
