Updated Privacy Policy | HGF-Ventures

Updated privacy policy according to EU-GDPR of the website www.hgf-ventures.com

This data protection declaration is based on the new EU basic data protection regulation, which will become valid on 25 May 2018. This concerns the data processing processes associated with visiting the www.hgf-ventures.com website.

1. Name and contact details of the controller and the company data protection officer
Data Protection Officer:

Highfly Ventures Ltd.

Thomas Sterk

21 P. Katelari St. 3rd Floor, 304

CY – 1097 Lefkosia

Cyprus

t.sterk@hgf-ventures.com

2. Collection and storage of personal data as well as type and purpose of their use

a) When you visit our website

When you visit our website www.hgf-ventures.com, the browser on your device automatically sends information to the server on our website. This information is temporarily stored in a so-called log file. The following information is recorded without your intervention and stored until it is automatically deleted:

IP address of the requesting computer,
Date and time of access,
Name and URL of the retrieved file,
Website from which access is made (referrer URL),
the browser used and, if applicable, the operating system of your computer as well as
the name of your access provider.

The mentioned data will be processed by us for the following purposes:

Ensuring a smooth connection of the website,
Ensure comfortable use of our website,
evaluation of system security and stability as well as
for other administrative purposes.

The legal basis for data processing is Art. 6 para. 1 sentence 1 letter f GDPR. Our legitimate interest follows from the purposes listed above for data collection. Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.

In addition, we use cookies and analysis services when you visit our website. You will find more detailed explanations under sections 4 and 5 of this data protection declaration.

b) When using our contact form

If you have any questions, we offer you the opportunity to contact us using the form provided on the website. A valid email address is required so that we know who sent the request and can respond to it. Further information can be provided voluntarily.

Data processing for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 sentence 1 letter a GDPR on the basis of your voluntary consent.

The personal data collected by us for the use of the contact form will be deleted at your request after your request has been processed.

3. Information disclosure

Your personal data will not be transmitted to third parties for purposes other than those listed below.

We will only pass on your personal data to third parties if:

you have given your explicit consent pursuant to Art. 6 para. 1 sentence 1 letter a GDPR,
the disclosure pursuant to Art. 6 para. 1 sentence 1 letter f GDPR is necessary to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
in the event that for the transfer pursuant to Art. 6, para. 1, sentence 1, letter 1 of the Basic Law c GDPR has a legal obligation, and
if this is legally permissible and necessary according to Art. 6 para. 1 sentence 1 letter b GDPR for the processing of contractual relationships with you.

4. Cookies

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do no damage to your end device, do not contain viruses, Trojans or other malware.

Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that we immediately become aware of your identity.

The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These will be deleted automatically after leaving our site.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for you for the purpose of optimizing our offer (see Section 5). These cookies enable us to automatically recognize when you return to our site that you have already been with us. These cookies are automatically deleted after a defined period of time.

The data processed by cookies are necessary for the purposes mentioned in order to protect our legitimate interests and those of third parties pursuant to Art. 6 para. 1 sentence 1 letter f GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our website.

5. Analysis tools

a) Tracking tools

The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 letter f GDPR. With the tracking measures used, we want to ensure that our website is designed to meet requirements and is continually optimized. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer. These interests are to be regarded as legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

b) Google Analytics (1)

For the purpose of demand-oriented design and continuous optimization of our pages, we use Google Analytics, a web analysis service provided by Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymised user profiles are created and cookies (see point 4) are used. The information generated by the cookie about your use of this website such as

* Browser type/version, * Operating system used, * Referrer URL (the previously visited page), * Host name of the accessing computer (IP address),

* Time of the server request,

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on the website activities and to provide further services associated with the use of the website and the Internet for the purposes of market research and demand-oriented design of these Internet pages.

This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company. Under no circumstances will your IP address be merged with other data from Google. The IP addresses are anonymized so that an assignment is not possible (IP masking).

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

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on https://tools.google.com/dlpage/gaoptout An opt-out cookie is set to prevent future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the optout cookie again.

For more information about privacy in connection with Google Analytics, please visit the Google Analytics Help Center (https://support.google.com/analytics/answer/6004245?hl=de).

Data protection authorities require the conclusion of an order data processing agreement for the permissible use of Google Analytics. A corresponding template is described in http://www.google.com/analytics/terms/de.pdf and provided by Google.

6. Social Media Plug-ins

We use social plug-ins of the social networks Facebook, Xing and Linkedin on our website on the basis of art. 6 par. 1 p. 1 letter f GDPR to make our company better known. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for data protection-compliant operation must be guaranteed by the respective provider. The integration of these plug-ins by us takes place in the way of the so-called two-click method around visitors of our web page in the best possible way to protect.

a) Facebook

Our website uses Facebook social media plug-ins to personalize their use. This is an offer from Facebook. When you visit a page of our website that contains such a plug-in, your browser establishes a direct connection to Facebook's servers.

The content of the plug-in is transmitted directly from Facebook to your browser and integrated into the website. By integrating the plug-ins, Facebook receives information that your browser has called up the corresponding page of our website, even if you do not have a Facebook account or are not currently logged on to Facebook. This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there.

If you are logged in to Facebook, Facebook can directly associate your visit to our website with your Facebook account. When you interact with the plug-ins, the information is also sent directly to a Facebook server and stored there. The information is also published on Facebook and displayed to your Facebook friends. Facebook may use this information for the purposes of advertising, market research and demand-oriented design of Facebook pages.

To this end, Facebook creates usage, interest and relationship profiles, e.g. to evaluate your use of our website with regard to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on our website and to provide other services associated with the use of Facebook.

If you do not want Facebook to associate the information collected through our website with your Facebook account, you must log out of Facebook before visiting our website. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights in this regard and setting options for the protection of your privacy can be found in the data protection information. (https://www.facebook.com/about/privacy/) von Facebook.

b) Xing

Plug-ins from Xing are integrated on our website. You can recognize the Xing plug-ins by the Xing logo on our site. When you access a page of our website that contains such a plug-in, a direct connection is established between your browser and the Xing server. Xing receives the information that you have visited our site with your IP address. If you click the Xing button while logged into your Xing account, you can link the contents of our pages on your Xing profile. This allows Xing to associate the visit to our pages with your user account. We would like to point out that, as the provider of these pages, we are not aware of the content of the data transmitted or how it is used by Xing. If you do not want Xing to associate your visit to our pages, please log out of your Xing account.

c) Linkedin

Plug-ins from Linkedin are integrated on our website. You can recognize the Linkedin plug-ins by the Linkedin logo on our site.

When you access a page of our website that contains such a plug-in, a direct connection is established between your browser and the Linkedin server. Linkedin receives the information that you have visited our site with your IP address. If you click the Linkedin button while logged into your Linkedin account, you can link the contents of our pages on your Linkedin profile.

Thus Linkedin can assign the visit of our pages to your user account. We would like to point out that we, as the provider of the pages, are not aware of the content of the transmitted data or its use by Linkedin. If you do not wish Linkedin to be able to associate your visit to our pages, please log out of your Linkedin user account.

7. Your rights as a data subject

As far as your personal data are processed during your visit to our website, you as "concerned person" have the following rights within the meaning of the GDPR:

7.1 Helpdesk

You may request information from us as to whether your personal data is processed by us. There is no right to information if the provision of the requested information would violate the duty of confidentiality pursuant to § 57 para. 1 StBerG or if the information must be kept secret for other reasons, in particular because of a predominant legitimate interest of a third party. Deviating from this, there may be an obligation to provide information if your interests outweigh the interest in confidentiality, especially taking into account impending damages. Furthermore, the right to information is excluded if the data are only stored because they may not be deleted due to legal or statutory retention periods or serve exclusively purposes of data protection or data protection control, provided that the provision of information would require a disproportionately high effort and processing for other purposes is excluded by suitable technical and organizational measures. If in your case the right to information is not excluded and your personal data is processed by us, you can request information from us about the following information:

Purposes of the processing:

Categories of personal data processed by you,
Recipients or categories of recipients to whom your personal data is disclosed, in particular recipients in third countries,
if possible, the planned duration for which your personal data will be stored or, if this is not possible, the criteria for determining the storage period,
the existence of a right to rectification, deletion or limitation of the processing of personal data concerning you or a right of opposition to such processing,
the existence of a right of appeal to a data protection supervisory authority,
if the personal data have not been collected from you as the data subject, the available information on the origin of the data,
the existence of automated decision making, including profiling and meaningful information on the logic involved, as well as the scope and intended effects of automated decision making,
if necessary, in the case of transfer to recipients in third countries, unless the EU Commission has decided on the adequacy of the level of protection pursuant to Art. 45 para. 3 GDPR, information on the appropriate guarantees provided for the protection of personal data pursuant to Art. 46 para. 2 GDPR.

7.2 Correction and completion

If you find that we have incorrect personal data from you, you can ask us to correct this incorrect data immediately. In the case of incomplete personal data concerning you, you may request the completion.

7.3 Erasure

You have a right of cancellation ("right to be forgotten"), unless the processing is necessary to exercise the right to freedom of expression, the right to information or to fulfil a legal obligation or to perform a task which is in the public interest and one of the following reasons applies:

The personal data are no longer necessary for the purposes for which they were processed.
The basis of justification for the processing was exclusively your consent, which you have revoked.
You have filed an objection to the processing of your personal data, which we have made public.
You have objected to the processing of personal data not made public by us and there are no overriding legitimate reasons for the processing.
Your personal data has been processed unlawfully.
The deletion of personal data is necessary to fulfil a legal obligation to which we are subject.
There is no claim for deletion if deletion is not possible or only possible with disproportionate effort in the case of legal, non-automated data processing due to the special type of storage and your interest in deletion is low. In this case, the restriction of processing takes the place of deletion.

7.4 Restriction of processing

You may request us to restrict processing if one of the following reasons applies:

You deny the accuracy of your personal data. In this case, the restriction may be required for the duration that enables us to verify the accuracy of the data.
The processing is unlawful and instead of deletion you request the restriction of the use of your personal data.
We no longer need your personal data for the purposes of processing, but for asserting, exercising or defending legal claims.
You have filed an objection pursuant to Art. 21 para. 1 GDPR. The restriction of processing may be required as long as it is not yet clear whether our justified reasons outweigh your reasons.
Restriction of processing means that personal data will only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest. Before we lift the restriction, we have a duty to inform you.

7.5 Data portability

You have a right to data transferability, provided that the processing is based on your consent (Art. 6 para. 1 sentence 1 letter a) or Art. 9 para. 2 letter a) GDPR) or on a contract to which you are a contracting party and the processing is carried out using automated procedures.

In this case, the right to data transferability includes the following rights, provided that this does not affect the rights and freedoms of other persons:

You can ask us to receive the personal data you have provided to us in a structured, common and machine-readable format.
You have the right to pass this data on to another person responsible without hindrance on our part. If technically feasible, you can request that we transfer your personal data directly to another person responsible.

7.6 Disagreement

If the processing is based on Article 6, paragraph 1, sentence 1, letter e) GDPR (performance of a task in the public interest or in the exercise of official authority) or on Article 6, paragraph 1, sentence 1, letter f) GDPR (legitimate interest of the person responsible or a third party), you have the right to object at any time to the processing of personal data concerning you for reasons arising from your particular situation. This also applies to profiling based on Art. 6 para. 1 sentence 1 letter e) or letter f) GDPR.

After exercising the right of objection, we will no longer process your personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

You may at any time object to the processing of personal data concerning you for direct marketing purposes. This also applies to profiling in connection with such direct advertising. After exercising this right of objection, we will no longer use the personal data concerned for direct marketing purposes.

You have the option of informing our company informally of your objection by telephone, e-mail, fax or to the postal address listed at the beginning of this data protection declaration.

7.7 Revocation of consent

You have the right to revoke your consent at any time with effect for the future. The revocation of the consent can be communicated informally by telephone, by e-mail, if necessary by fax or to our postal address. The legality of the data processing, which is based on the consent until receipt of the revocation, is not affected by the revocation. After receipt of the revocation the data processing, which was based exclusively on your consent, is stopped.

7.8 Grievance

If you believe that the processing of personal data concerning you is unlawful, you may lodge a complaint with the supervisory authority responsible for the place of the alleged infringement.

8. Data integrity

We use the most common SSL (Secure Socket Layer) method in connection with the highest level of encryption supported by your browser. Usually this is a 256 bit encryption.

If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form is indicated by the closed display of the key or lock symbol in the lower status bar of your browser.

We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

9. Up-to-dateness and amendment of this data protection declaration

This privacy statement is dated May 25, 2018 and we reserve the right to update the privacy statement in due course in order to improve data protection and/or adapt it to changes in government practice or case law.