Privacy policy

Status April 2021

Table of contents

I. Name and address of the person responsible
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Provision of the website and creation of log files
VI. Use of cookies
VII. Hosting
VIII. Email contact

I. Name and address of the person responsible

The responsible person within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:
NAS Real Investment Management GmbH
Goetheplatz 4
60311 Frankfurt am Main
Germany
069913948000
info@nas-real.com
www.nas-invest.com

 

II. Contact details of the data protection officer

The data protection officer of the data controller is:
DataCo GmbH
Dachauer Street 65
80335 Munich
Germany
+49 89 7400 45840
www.dataguard.de

III. General information on data processing

1. Scope of the processing of personal data

As a matter of principle, we only process personal data of our users insofar as this is necessary for the provision of a functional website as well as our contents and services. The processing of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases in which obtaining prior consent is not possible for actual reasons and the processing of the data is required by legal regulations.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) sentence 1 lit. a DSGVO serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) sentence 1 lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) sentence 1 lit. c DSGVO serves as the legal basis.

In the event that vital interests of the data subject or another natural person make it necessary to process personal data, Article 6 (1) sentence 1 lit. d DSGVO serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6 (1) sentence 1 lit. f DSGVO serves as the legal basis for the processing.

III. Data deletion and storage period

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.

IV. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. Right to information

You may request confirmation from the controller as to whether personal data concerning you are being processed by him.

If there is such processing, you can request information from the controller about the following:
  • the purposes for which the personal data are processed;
  • the categories of personal data which are processed;
  • the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  • the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage duration;
  • the existence of a right to rectify or erase personal data concerning you, a right to have processing restricted by the controller or a right to object to such processing;
  • the existence of a right of appeal to a supervisory authority;
  • any available information on the origin of the data if the personal data are not collected from the data subject;
  • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 of the GDPR in connection with the transfer.

This right of access may be restricted to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

2. Right of rectification

You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

Your right to rectification may be limited to the extent that it is likely to render impossible or seriously prejudice the achievement of the research or statistical purposes and the limitation is necessary for the fulfilment of the research or statistical purposes.

3. Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions:
  • if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you refuse to erase the personal data and instead request the restriction of the use of the personal data;
  • the controller no longer needs the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims, or
  • if you have objected to the processing pursuant to Art. 21 (1) DSGVO and it has not yet been determined whether the legitimate grounds of the controller outweigh your grounds.
Where the processing of personal data relating to you has been restricted, those data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Your right to restrict processing may be limited to the extent that it is likely to render impossible or seriously impede the achievement of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

4. Right to erasure

a) Obligation to delete

You may request the controller to erase the personal data concerning you without delay and the controller is obliged to erase this data without delay if one of the following reasons applies:
  • The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  • You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a DSGVO and there is no other legal basis for the processing.
  • You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
  • The personal data concerning you has been processed unlawfully.
  • The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 (1) DSGVO.
b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to, or copies or replications of, that personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary
  • to exercise the right to freedom of expression and information.
  • for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, where the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
  • for the assertion, exercise or defence of legal claims.

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed of these recipients by the controller.

6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that
  • the processing is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b DSGVO and
  • the processing is carried out with the aid of automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability shall not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6 (1) sentence 1 lit. e or f DSGVO; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

You also have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR.

Your right to object may be restricted to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
  • is necessary for the conclusion or performance of a contract between you and the responsible person,
  • is authorised by legislation of the Union or the Member States to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
  • is done with your express consent.
However, these decisions must not be based on special categories of personal data pursuant to Art. 9(1) of the GDPR, unless Art. 9(2)(a) or (b) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

With regard to the cases referred to in 1 and 3, the controller shall take reasonable steps to safeguard the rights and freedoms of, and your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

10. Right to complain to a supervisory authority

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 residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

V. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:
  • Date and time of the retrieval
  • The operating system of the user
  • The user’s internet service provider
  • Information about the browser type and version used
  • The IP address of the user
  • Websites from which the user’s system accesses our website
  • Date and time of access
This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of the data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 p. 1 lit. f DSGVO.

3. Legal basis for the data processing

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 p. 1 lit. f DSGVO.

4. Duration of the storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is no longer possible.

5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

VI. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. When a user calls up a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change. The following data is stored and transmitted in the cookies:
  • Language settings
The user data collected in this way is pseudonymised by technical precautions. Therefore, it is no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users.

2. Purpose of the data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

The user data collected through technically necessary cookies are not used to create user profiles.

3. Legal basis for the data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 p. 1 lit. f DSGVO.

4. Duration of storage, possibility of objection and elimination

Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

If you use a Safari browser from version 12.1, cookies are automatically deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures.

VII. Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is:

United Domains, Hetzner Server

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The information stored is:
  • Date and time of the retrieval
  • The operating system of the user
  • The user’s internet service provider
  • Information about the browser type and version used
  • The IP address of the user
  • Websites from which the user’s system accesses our website
  • Date and time of access
This data is not merged with other data sources. The collection of this data is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be collected.

The location of the website’s server is geographically in Germany.

VIII. Email contact

1. Description and scope of data processing

On our website, it is possible to contact us via the email address provided. In this case, the user’s personal data transmitted with the email will be stored.

The data is used exclusively for processing the conversation.

2. Purpose of the data processing

In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

3. Legal basis for the data processing

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f DSGVO. If the email contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.

4. Duration of the storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by email, he or she can object to the storage of his or her personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of contacting us will be deleted in this case.

IX. Application by email

1. Scope of the processing of personal data

You can send us your application by email. We will collect your email address and the data you provide in the email.

2. Purpose of the data processing

The processing of personal data from your application email is solely for the purpose of processing your application.

3. Legal basis for the data processing

The legal basis for the processing of your data is the initiation of a contract at the request of the data subject, Art. 6 para. 1 p.1 lit. b Alt. 1 DSGVO and § 26 para. 1 p. 1 BDSG.

4. Duration of the storage

After completion of the application process, the data will be stored for up to six months. Your data will be deleted after the six months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

5. Possibility of objection and removal

The applicant has the possibility to object to the processing of personal data at any time. In such a case, the application can no longer be considered.

All personal data stored in the course of electronic applications will be deleted in this case.

This privacy policy was created with the support of DataGuard.