Privacy Policy

Privacy Policy

(Information in accordance with Section 13 Para. 1 Telemediengesetz [German Telemedia Act])

This Privacy Policy applies to the web services and websites of Ligatus GmbH, Hohenstaufenring 30-32, D-50674 Cologne, Germany - hereinafter referred to as „Ligatus“ - and also to the microsites operated by Ligatus for its customers and, if applicable, further advertising materials which are maintained by Ligatus for its customers, in particular also advertising materials for the delivery of personalised and behaviour-based advertising for the Internet (see section 4 of this data protection declaration).

This Privacy Policy is always to be regarded as part of the respective web presence which directly refers to this site (e.g. under “Privacy” or “Privacy Policy”).

Ligatus takes the protection of your personal data very seriously. We would like to inform you about when we collect what data and how we use it. We have implemented extensive technical and organisational measures to ensure compliance with applicable provisions on data protection and data security by Ligatus and as well contracted third party providers. Please note that amendments to this Privacy Policy may be required due to the ongoing development of our websites and the implementation of new technologies to improve our web services. We therefore recommend frequently referring back to this Privacy Policy and reading through the current up-to-date version, which is always available online under http://www.ligatus.com/privacy-policy.

What is personal information?

Personal information is any information that can be used to obtain personal or factual details about you (such as name, address, telephone number, date of birth or e-mail address). Information that cannot (directly or indirectly) be associated with you personally (or only with disproportionate effort), for example anonymous information, is not personal information.

What information do we collect and process?

You can use a portion of our online content without providing personal information.

a) Contact forms

If you however decide to request further information via the contact forms provided on our websites or the microsites operated on behalf of our customers, we will ask for your name and further personal information in order to handle your personal request or to provide the services you requested from us or our customers. Please note that the exact scope of the collected information varies depending on the relevant campaign and services offered by the relevant customer, and will be specified in the contact form of each campaign (all mandatory fields are marked with *). You can freely decide whether or not you want to provide the requested information. However, without this information, we are unable to make the desired services available to you.

b) User account (Direct Ads)

Certain services on our websites are only available to paying users and can only be used by registered users with a user account. We store your e-mail address during registration. The e-mail address serves as a user name to identify your member account, and to conduct relevant correspondence with you (e.g. setting up and maintaining your user account). As part of the registration process, we also collect your first and last name, your gender, and information about your company affiliation, mailing address, and telephone, as well as information regarding your chosen means of payment, credit card, and bank account information, if applicable, in order to bill you for the services you choose to use and to ensure that you receive personalised, competent service. All mandatory information required in order to register is marked accordingly. All further information is provided voluntarily; this data is used for the purposes stated, or to improve our online services.

By registering with our websites, you declare your agreement with the General Terms and Conditions of Ligatus and the use by Ligatus of your abovementioned personal information in accordance with this Privacy Policy.

If you wish to register as a user of our web services and open a user account, please select for your own safety a secret and secure password in order to ensure the confidentiality of your data. Your password is transmitted to and stored on our servers in encrypted form, and we are unable to access and read it; in the event that you forget your password, please use the “Forgot your password?” function provided on the website to create a new, secure password.

If you delete your account in the login area under “Account Settings” (by selecting “Delete Account”), your data will be deleted. If deletion is not possible for legal reasons, access to the data in question shall instead be blocked. Please note, however, that we may be unable to continue offering some or all of the services provided on our websites requiring registration in the event that your data is deleted or blocked.

c) Ligatus newsletter

As part of our web services, we offer a regular subscription to our Ligatus newsletter. When requested, the newsletter provides you with free, up-to-date information on selected top investment opportunities and financial planning and insurance products. To register without Ligatus newsletter service, we need your first and last name, your gender, and the e-mail address at which you wish to receive the newsletter. If you wish to subscribe to the Ligatus newsletter, we ask that you provide us with the following declaration of consent:

I would like to regularly receive the Ligatus newsletter, and agree that my e-mail address, my first and last name, and my gender, as well as any data voluntarily provided, be used for this purpose. I can revoke this declaration of consent at any time by an e-mail sent to info@ligatus.com, or by writing to Ligatus GmbH, Hohenstaufenring 30-32, D-50674 Cologne, Germany, such revocation to take effect for the future. No additional fees beyond the normal transmission fees of my e-mail or Internet provider shall apply. In the event that my consent is revoked, I shall not, or shall no longer, be able to receive the Ligatus newsletter. I have read and accept the current privacy policy.

d) “Double opt-in procedure”

In order to verify your registration when setting up a user account and/or to acquire your consent when ordering the Ligatus newsletter, we use the “double opt-in procedure”. This means that we will only set up your user account or send you the Ligatus newsletter once you have confirmed your registration via a confirmation e-mail sent to you for this purpose, by clicking on the link contained therein. By doing this, we wish to ensure that only you yourself as the owner of the e-mail address given are able to make use of our services.

How does Ligatus use your personal information

Personal information is also requested by us for billing and promotional purposes and processed by us or by our partners and customers (e.g. when ordering information or premiums). The usage of your personal information varies depending on the relevant campaign and customer. You will be informed thoroughly about any usage of your personal information on the relevant website or within the relevant campaign.

Your personal information is not used for purposes that you did explicitly agree to when requesting our services or within the scope of the relevant campaign. Without your consent, your information will not be used e.g. for marketing purposes. You will only receive advertising if you have given your explicit consent. You can revoke your consent any time by using our contact form or sending an email to info@ligatus.com. However, in this case Ligatus may no longer be able to provide the offered services.

In addition to personal information collected about you via our contact forms or microsites operated on behalf of our customers or business partners, which will strictly be used to provide the relevant services to you, our web servers log general information on the usage of our websites (such as: date and time, visited websites - e.g. when each page was viewed or which page was visited most frequently).

Such log data is processed for system security reasons (to prevent abuse of our web services), to improve our websites and web services and as well for statistical purposes (number of users and page views). However, we do not analyse personal information.

Delivery of personalised or behaviour-based advertising (behavioral targeting)

In certain cases, we showcase advertising to you on the websites of our partners and for our customers, which are automatically selected on the basis of your surfing behaviour, in order to optimise the quality of the advertising notices for you (so-called "personalised" or "behaviour-based" advertising delivery and "behavioral targeting". The objective of this system is to only demonstrate to you those commercials which may correspond to your interests. Advertising notices which are unlikely to be of interest to you or which are irrelevant will not be shown to you by the activated behavioral targeting system of Ligatus and will be disabled.

In such a case, this section 4 of the data protection declaration applies as part of the respective web-based services of our partners or customers, from which (for example under "data protection" or "data protection declaration" direct reference was made or a link was created. We wish to disclose to you in a transparent manner how the behavioral targeting works, which data is gathered in the process, how this data is used and for what purpose and how you can object to the behavioral targeting function at any time and block it.

As a German/Europeancompany, the protection of your data is a priority for Ligatus, also in the course of the delivery of behaviour-based advertising and Ligatus only uses anonymised data to improve advert quality. Therefore, an identification of your person is not possible either for Ligatus or the respective operator of the website of our partners and customers which you are visiting. You can yourself decide at any time whether you would like to continue seeing personalised banner from Ligatus.

User data is processed exclusively in European computer centres.

Ligatus has voluntarily obliged itself to comply with the OBA framework of the EDAA / AB Europe and provides regular proof of this within the framework of its annual certification in accordance with these parameters.

a) How does behavioral targeting work in individual cases?

When visiting the website of one of our partners or customers, a cookie file is stored on your computer. Cookies are small text files which are deposited by your web browser in a folder on your computer which is designated for this purposes and which contains a single character string as a means of identification. The cookie does not store your IP address or any data that allows you to be identified. The same character string is also saved on our servers. The next time you visit one of our partners' websites, only the character string is read which identifies the Internet browser you are using. This allows us, for example, to identify which page you have accessed for our partner and which advert you have been shown, without this being linked to your identity. Furthermore, all of the cookies created by us are given an expiry data and automatically expire after no more than 13 months. Without a valid cookie file, the character strong saved on our servers is no longer to be assigned for us.

Important: Using cookies we cannot ever collect your personal data. For example, when you enter an email address or delivery address, or any other personal data, we cannot see your input and cannot therefore process or store it. We do not know your name, address or workplace, nor do we know your gender, age, email address or any other personally identifiable information about you. Even the IP address of your computer is not stored! You can view the data stored in the cookie on your computer. Please refer to your web browser’s help directory or your web browser’s FAQ to learn how cookies are stored and how to read their content. The information contained within the cookie is the exact data that we can see Cookie technology does not allow viruses, trojans or other harmful programs to be placed on your computer.

A full list of the cookies used by Ligatus and their individual functions can be downloaded here at any time. Should you not agree to the saving of cookies on our part, you can retrieve your cookie status here at any time, and also deactivate the saving of behavioral targeting cookies by us. Therefore you can object to the personalised adverts from Ligatus at any time.

b) How can I check whether personalised advertising from Ligatus is enabled on my computer?

Here you can check whether personalised advertising from Ligatus is enabled (“Opt-In”) or disabled (“Opt-Out”) in your computer.

c) How can I disable personalised advertising from Ligatus banners?

If you do not agree to the storing of cookies by us, you can check your cookie status at any time here and disable the storage of retargeting cookies by us and therefore decline personalised adverts from Ligatus.

This means that in future you will receive random advertising that is not targeted to your interests. Please note that the "opt-out" and "opt-in" functions offered are also controlled using cookies. This means that deleting all cookies on your computer means that you will have to opt-out again.

It is also the case that the deletion of all cookies on your computer does not lead to no personalised advertising being notified to you on a permanent basis. Therefore, you must use the following link to the "opt out" function which is provided, should you not wish for behaviour-based advertising to be delivered to your computer or your end devices. At the following address http://www.ligatus.com/privacy-policy#cookie_status you can change your current cookie status at any time.

Finally, please note that we are continuously expanding our range of products. As this will technically involve a new system, the introduction of a new opt-out may be necessary, even if you have already opted prior to its introduction.

d) Can other forms of personalised advertising be disabled in addition to Ligatus?

The options described in this section refer only to the personalised adverts offered by Ligatus. If you wish to disable personalised advertising from other providers, you can do this via their respective websites.

There is an option to change your settings collectively for various providers under preference management on “Your Online Choices”:http://www.youronlinechoices.com/de/praferenzmanagement/.

Anonymous data/use of cookies

We also use cookies on the Ligatus websites. Cookies are small text files, stored by your web browser in a dedicated directory on your computer or mobile device. Cookies are solely used to identify your web browser in an anonymous manner to optimise the display of targeted advertising messages on our websites or the websites of our partners (see in particular the following section 6 concerning the use of Google Analytics and Google Remarketing).

Our cookie files only contain an automatically generated ID number and a time stamp and do not support a personal reference. We neither know your name, the place you live or work, nor do we know your gender, your age, your e-mail address or any other personally identifiable information about you. The IP address of your device will also not be stored. You can view the data stored in the cookie on your computer. Please refer to your web browser’s help directory to learn how cookies are managed. The information contained within the cookie is the exact data that we can see Cookie technology does not allow viruses, trojans or other malware to be placed on your computer.

You can also use our websites without the use of cookies enabled. Most browsers accept cookies automatically. You can disable the storage of cookies or set your browser to notify you before accepting the storage of cookies. Please note that users who do not accept the storage of cookies may not be able to access certain functionality of our websites, or can only use our websites with considerable difficulty.

Further information and a full list of the cookies which are used by Ligatus on its own websites or on those of customers or partners, as well as their individual functions, can be downloaded here at any time. In addition, you can generally prevent the storing of cookies by adjusting your browser settings accordingly.

Usage of Google Analytics and Google Remarketing

a) The Ligatus websites use Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA („Google“). Google Analytics uses cookies, which are text files placed on your computer or your mobile device, to help the website analyse how users use the site. The information generated by the cookie about your use of the website will be transmitted and stored by Google on servers in the United States.

Please note, that the application of Google Analytics within our web services has been enhanced with the code „gat._anonymizeIp();“ to enable the anonymous logging of IP addresses (so-called “IP-masking”). Prior to the transmission, your IP address will be truncated by Google within the member states of the European Union or other parties to the accord on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and truncated there. Google will not associate your IP address with any other data collected or held by Google.

Google uses this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide the website operator with more services related to the website and internet use. Google may also transmit the information to third parties when required by law or when third parties process the information on behalf of Google.

You can disable the use of cookies by selecting the appropriate settings on your browser, however please note, that if you do so, you may not be able to use the full functionalities of this website.

You can also disable the collection of the information generated by the cookie concerning your use of the websites and the processing of these data by Google, by installing the browser plug-in available for download via the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the above mentioned browser plug-in or when using mobile devices, you can disable the collection of the information generated by the cookie by clicking the following link: Google Analytics deaktivieren

An opt-out cookie will be then stored that disables the collection of your information for future visits of our websites.

Further information is available here:http://tools.google.com/dlpage/gaoptout?hl=en respectively under http://www.google.com/intl/en/analytics/learn/privacy.html (general informationen on Google Analytics and privacy).

b) We also allow Google to place cookies on our websites for the purpose of use-based online advertising

The cookie stored on your computer by Google allows the anonymised recognition of your browser by Google and gathers information about your activities on the websites you visit (e.g. web surfing behaviour, subpages visited on our Internet content, etc.) Use profiles are generated from this data, using a pseudonym that does not allow conclusions to be drawn about the user and therefore cannot be used to identify a specific user. The information collected by the cookie concerning your use of this website (including your IP address) is transferred to a server in the United States of America and stored there. Google then removes the last three digits of the IP address, thus ensuring that the IP address can no longer be uniquely identified. Under no circumstances will Google associate your IP address with other information held by Google. Google complies with the data privacy provisions of the “US Safe Harbor” agreement and is registered with the “Safe Harbor” accord of the United States Department of Commerce.

This procedure, known as “Google remarketing”, allows anonymous recognition by Google’s websites. Your browser is identified when advertising content is supplied and assigned to a particular target group. With the aid of this information, it is possible to show you advertisements that are more relevant and address your particular interests. Google uses this information to evaluate your use of the website, to compile reports on website activity for the operators of the websites, and to provide additional services related to the use of the website and the Internet. Google may also transmit this information to third parties when required by law or when third parties process such information on behalf of Google.

Depending on your interests, a targeted provision of advertisements relevant to you is enabled when you visit the websites of other providers.

You may object at any time to the future collection and storage of your data by Google. Call up your display settings in Google under www.google.de/settings/ads and deactivate the display of interest-related advertisements by Google under “deactivation settings”. This will prevent Google from displaying targeted advertising for you. An “opt out” cookie is then placed that prevents future collection of your data when you visit this website. Please note that, if you delete all cookies from your computer, the deactivation cookie is deleted along with them, and must be stored again if needed.

You can find further information regarding the terms of Google’s privacy policy at http://www.google.com/intl/de/policies/privacy.

In addition, as a general matter, you can prevent the placing of cookies by adjusting your browser settings accordingly.

Is personal information forwarded to third parties?

A forwarding on of your data to other companies, such as our co-operation or advertising partners, only takes place if your have expressly agreed to a transmission of your data and receipt of adverts from these companies within the framework of the respective campaign.

In certain cases, we are also required by law to disclose your personal information to third parties. This is for example the case when the suspicion of a criminal offence or a misuse of our websites occurs. We are then required to disclose your data to law enforcement authorities.

Outside of the cases described in this data protection declaration, your data is not forwarded on to third parties and, your information is solely stored in our databases / on our servers (or on the servers of third party providers).

Hyperlinks to other websites

In addition, our websites contain hyperlinks to websites offered by third parties When clicked, the hyperlinks redirect you from our website directly to the website of another provider. You can recognize this redirection process by the change of the URL in your web browser’s address bar. If you have been forwarded to the website of a cooperation or promotional partner, the use of your personal information will only be subject to the privacy policy of the relevant provider. We cannot take any responsibility for the privacy practices of third party´s websites because we do have no control over their compliance with data protection regulations.

Protection of minors

Persons under 18 years are excluded from our services and from providing any personal information without the consent of their parents or guardians. We do not request personal information from children and adolescents. We do not knowingly collect such data and do not disclose it to third parties.

How we keep your information secure

When we collect information, we solely store your data on highly protected servers in Germany and the EU. Access to our IT infrastructure is strictly limited to authorised persons who are involved in the technical, commercial or editorial support.

In order to avoid loss or misuse of data stored by us, we have taken all necessary and extensive technical and operational safety precautions, which are regularly checked and updated based on technological advancements.

However, we would like to inform you that because of the nature of the Internet, the provisions of data protection and data security measures described in this Privacy Policy may not be observed by any third parties or institutions beyond our control. Especially unencrypted data transmission – even when sent via e-mail – can be read by third parties. We have no technical influence on this. The user has the responsibility to protect the information he provides from misuse by encryption, selection of a secure password or other means.

Details regarding your personal information stored by Ligatus/deletion

Ligatus does not store your information any longer than the period allowed by law.

Upon your request, we will gladly inform you at any time whether we are storing any information about you, and which data this might be.

If we are storing erroneous personal information about you despite our attempts to ensure that our data is correct and current we shall promptly correct such mistakes at your request. If you wish that the stored data be deleted, this shall also be carried out promptly upon request. If deletion is not possible for legal reasons, access to the data in question shall instead be blocked. However, please note that we may be unable to continue offering some or all of the services provided on our websites in the event that your data is deleted or blocked.
In these cases please refer to:

Ligatus GmbH
Hohenstaufenring 30-32
D-50674 Cologne
Germany
E-Mail: info@ligatus.com

Data Privacy Officer

If you have further comments or questions about our Privacy Policy or general privay issues at our company, please contact our Data Privacy Officer (DPO):

Stephan Krämer, LL.M., Attorney at Law (Germany)
Kinast & Partner Rechtsanwälte

http://www.kinast-partner.de/

As of: December 2014