Our privacy policy is modular in structure. It consists of a general part for all processing of personal data and processing situations (I. General) and a special part, the content of which relates in each case only to the processing situation specified there (II., III., IV.). In order to be able to find the parts relevant to you, please refer to the following overview for the subdivision of the data protection notice:
For whom is this part relevant?
I. General information on data processing:
Everyone
II. Data processing when visiting the Website:
Website visitors
III. Data processing when visiting the LinkedIn Page:
LinkedIn page visitors
IV. Data processing when visiting the Twitter Page:
Twitter page visitors
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States and other provisions of data protection law for the processing of data to provide the Website is:
Robin Capital GmbH
c/o GRAEF Rechtsanwälte PartG mbB
Jungfrauenthal 8
20149 Hamburg
Website: robincap.com
Mail: hello@robincap.com
"Controller" means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
I. General information on data processing
1. Scope of the processing of personal data
Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations which are necessary to carry out pre- contractual measures.
Insofar as processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.
If the processing of the data requires the storage of information in your terminal equipment or access to information already stored in the terminal equipment, § 25 para. 1, 2 TTDSG serves as the legal basis for this.
3. Data deletion and storage period
The personal data of the user will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU ordinances, laws or other regulations to which the person responsible is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.
4. Contact
You can contact us via our contact form, via e-mail, via phone or by mail. Your details and attachments from the inquiry, including the contact details you provide there, will be stored by us solely for the purpose of processing the inquiry and in the event of follow-up questions. In the case of the contact form, your connection data such as IP address and the date and time of sending are also processed. If you contact us by e-mail, your e-mail address and the date and time of sending will be processed. If you contact us by telephone, the telephone number will be processed. If you write to us by letter, we process your address data and date. In this context, the data will not be passed on to third parties. The data will not be passed on to third parties in this context.
The legal basis for the processing of the data is Art. 6 para. 1 lit. f GDPR. Our interest in answering your inquiry outweighs your interest; since you are writing to us, an answer is also in your interest and you are aware that we must process your data in order to answer your inquiry.
If the contact aims at the conclusion of a contract, the legal basis for processing is Art. 6 para. 1 lit. b GDPR.
The data will be deleted as soon as they are no longer required for the purpose of their collection. This is the case when the respective conversation with the user has ended. The conversation is terminated when it can be concluded from the circumstances that the matter in question has been finally clarified.
5. Recipients of your data
Within our company, the bodies that have access to your data are those that require it for the fulfillment of their processing purposes. This also applies to the service providers and vicarious agents we use. All offices and persons who work with your data are bound to data secrecy and have been made aware of the sensitive handling of personal data.
Your data will only be passed on outside the company if this is in accordance with data protection regulations. This is the case if the transfer is necessary to fulfill the purposes or if we have obtained your consent for the use and transfer of the data. The following categories of recipients may receive your data:
Service providers for the operation of our Website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 lit. b or lit. f DSGVO, insofar as they are not processors.
Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 lit. b or lit. f DSGVO.
In the context of visiting the Website, further recipients come into consideration, which are listed in the appropriate places under "II.
6. Data sources
We receive your personal data mainly directly from you and, if necessary, also use public sources (Websites, contact directories, etc.) for initial contact.
If we receive your data from other third parties (for example, recommendations from other partners), we will inform you about these data sources during the initial contact.
7. Rights
If your personal information is processed, you have the following rights.
a) Right of access
You have the right to obtain from us confirmation as to whether or not personal information concerning you are being processed, and, where that is the case, access to the personal data and the following information:
(1) the purposes of the processing;
(2) the categories of personal data concerned;
(3) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
(4) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(5) the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal information or to object to such processing;
(6) the right to lodge a complaint with a supervisory authority;
(7) where the personal data are not collected from you, any available information as to their source;
(8) the existence of automated decision-making, including profiling, referred to in Art. 22 para. 1 and 4 and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.
b) Right of rectification
You have the right to obtain from us within undue delay the rectification of inaccurate or incomplete personal information. Taking into account the purposes of the processing, you shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
You shall have the right to obtain from us restriction of processing where one of the following applies:
(1) the accuracy of the personal data is contested by yourself, for a period enabling us to verify the accuracy of the personal data;
(2) the processing is unlawful and the data subject opposes the erasure of the personal information and requests the restriction of their use instead;
(3) we no longer need the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(4) You have objected to processing pursuant to Art. 21 para. 1 pending the verification whether the legitimate grounds override those of the data subject.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
If you have obtained restriction of processing pursuant to the above, you shall be informed by us before the restriction of processing is lifted.
d) Right to erasure (‘right to be forgotten’)
You shall have the right to obtain from us the erasure of personal information concerning without undue delay and we shall have the obligation to erase personal information without undue delay where one of the following grounds applies:
(1) the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(2) you withdraw consent on which the processing is based according to Art. 6 para.1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, and where there is no other legal ground for the processing;
(3) you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para 2 GDPR;
(4) the personal information has been unlawfully processed;
(5) the personal information has to be erased for compliance with a legal obligation in the European Union
(6) the personal information has been collected in relation to the offer of information society services referred to in Article 8 para.1.
Where we have made the personal information public and is obliged pursuant to the above to erase the personal information, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The right to erasure shall not apply to the extent that processing is necessary:
(1) for exercising the right of freedom of expression and information;
(2) for compliance with a legal obligation which requires processing by the European Union or for the performance of a task carried out in the public interest
(3) for reasons of public interest relating to public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the DPA;
(4) for archiving, scientific or historical research purposes in the public interest or for statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to make it impossible or seriously impede the attainment of the objectives of such processing, or
(3) for the establishment, exercise or defense of legal claims.
e) Notification regarding rectification or erasure of personal data or restriction of processing
We shall communicate any rectification or erasure of personal data or restriction of processing carried to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request it.
f) Right to data portability
You have the right to receive the personal information, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal information has been provided, where:
(1) the processing is based on consent pursuant to Art. 6 para 1 lit. a or Art. 6 para 1 lit. b or Art. 2 para 2 lit. a
(2) the processing is carried out by automated means.
The right shall not adversely affect the rights and freedoms of others.
In exercising your right to data portability you shall have the right to have the personal information transmitted directly from one controller to another, where technically feasible.
The exercise of this right shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
g) Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning him or her which is based on Art. 6 para. 1 lit e) or lit. f). We shall no longer process the personal information unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where personal information is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.
At the latest at the time of the first communication with you, the right referred to above shall be explicitly brought to your attention shall be presented clearly and separately from any other information.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise his or her right to object by automated means using technical specifications.
h) Right to revoke the declaration of consent
You have the right to revoke your data protection declaration of consent at any time. Revocation of your consent does not affect the legality of the processing that has taken place on the basis of your consent until revocation.
i) Automated individual decision-making
You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you
This shall not apply if the decision:
(1) is necessary for entering into, or performance of, a contract between you and us
(2) is authorized by European Union law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
(3) is based on your explicit consent.
We shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express our point of view and to contest the decision.
Decisions shall not be based on special categories of personal data referred to in unless Art. 9 para.2 lit. a) or lit g) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
j) Right of complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the European Member State where you reside, work or suspect of infringement, if you believe that the processing of personal information concerning you is not in compliance with GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
II. Data processing when visiting the Website robincap.com
1. Provision of the Website and creation of log files
Whenever our Website is accessed, our system automatically collects data and information from the computer system of the calling computer. The following data is collected for a limited time:
1. Information about the type of browser and the version and language used.
2. The operating system of the user
3. The Internet service provider of the user
4. The IP address of the user
5. Date and time of access
6. The amount of data transferred
7. The message whether the call was successful
8. The GMT time zone difference
9. Websites from which the user's system accesses our Website
10. Websites that are accessed by the user's system via our Website
The data is stored in the log files of our system. This data is only needed for the analysis of possible errors and will be deleted within 30 days after the end of an event at the latest. The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR. The temporary storage of the IP address by the system is necessary to enable the Website to be delivered 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, the data serves us to optimize 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 and no conclusions are drawn about your person. 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 of objection on the part of the user.
2. Use of cookies
We use so-called session or flash cookies on our Website and in our Application. Cookies are text files that are stored in or by the Internet browser on the user's computer system. When a user visits 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 the next time the Website is accessed. Some functions of our Website cannot be offered without the use of cookies. These may include in particular: Session cookies (which store shopping cart contents, login status or language settings), opt-out cookies (which can be used to revoke consent to data processing), cookies from payment service providers (which are only used to prepare payments or verify payment legitimacy), pure counting cookies (which prevent Websites from being overloaded) or Flash cookies (which are used to play media content). For these it is necessary that the browser is recognized even after a page change. The user data collected with technically necessary cookies is not used to determine the identity of the user or to create user profiles. The legal basis for the processing of personal data by means of technically necessary cookies is § 25 para. 2 TTDSG and Art. 6 para. 1 lit. f) GDPR. As the usage of these cookies is technically necessary, there is no possibility for the user to object. Insofar as we use cookies that are not technically necessary, you will find the relevant information in the following information on the individual services.
3. Newsletter dispatch
We offer the subscription to a newsletter. When you subscribe to our newsletter, the following "newsletter data" is collected, stored and processed by us: the page from which the page was requested (so-called referrer URL); the date and time of the request; the description of the type of web browser used; the IP address of the requesting computer, which is shortened so that a personal reference is no longer possible; the e-mail address; the date and time of registration and confirmation.
We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the e-mails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our Website. For the evaluations, we link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links contained in the newsletter also contain this ID. The data is collected exclusively pseudonymously, i.e. the IDs are not linked to your other personal data, a direct personal reference is excluded.
The newsletter data is processed for the purpose of sending the newsletter. In the course of registering for our newsletter, you consent to the processing of your personal data (legal basis is Art. 6 para. 1 lit. a DSGVO). For the registration to our newsletter, we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data. You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter e-mail, by e-mail to hello@robincap.com or by sending a message to the contact details provided in the imprint.
4. Newsletter dispatch using Mailchimp
We use Mailchimp by The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE Suite 5000, Atlanta, GA 30308 USA (Mailchimp) to send our newsletter. This allows us to contact subscribers directly. In addition, we analyze your usage behavior in order to optimize our offer. For this purpose, we share the following personal data with Mailchimp: email address [first name] [last name] [phone number] [Our email sends include a link that allows you to update your personal data].
Mailchimp is a recipient of your personal data and acts as a processor for us as far as sending our newsletter is concerned. The processing of the data provided under this section is not required by law or contract. Without your consent and the transmission of your personal data, we cannot send out a newsletter to you.
In addition, Mailchimp collects the following personal data using cookies and other tracking methods: Information about your terminal device (IP address, device information, operating system, browser ID), information about the application you use to read your emails, and other information about hardware and internet connection. In addition, usage data is collected such as date and time, when you opened the email and browser activity (e.g. which emails/web pages were opened). Mailchimp needs this data to ensure the security and reliability of the systems, compliance with the terms of use and the prevention of abuse. Furthermore, Mailchimp evaluates performance data, such as the delivery statistics of emails and other communication data. This information is used to create usage and performance statistics of the services. This corresponds to the legitimate interest of Mailchimp (according to Art. 6 para. 1 lit. f DSGVO).
Mailchimp additionally collects information about you from other sources. In an unspecified period and scope, personal data is collected via social media and other third-party data providers. We have no influence on this process. For more information on objection and removal options to Mailchimp, please visit: https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts. The legal basis for these processing operations is your consent according to Art. 6 (1) lit. a DSGVO. You can revoke your consent to the processing of your personal data at any time. A corresponding link can be found in all mailings. In addition, the revocation can be made via the specified contact options. By declaring the revocation, the lawfulness of the processing carried out so far is not affected. Your data will be processed as long as a corresponding consent is available.
Apart from this, they will be deleted after termination of the contract between us and Mailchimp, unless legal requirements make further storage necessary. Mailchimp has implemented compliance measures for international data transfers. These apply to all global activities where Mailchimp processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs). For more information, please visit: https://mailchimp.com/en/legal/data-processing- addendum/
5. Social Media Links
We maintain online presences on social networks and platforms to communicate with clients, interested parties, and users who are active on those networks, and to be able to inform clients, interested parties, and users of our services.
Our Website therefore links to the Website of LinkedIn, operated by LinkedIn Corp, 1000 W Maude Ave, Sunnyvale, CA, 94085-2810, USA, or, if you reside in the EU, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Otherwise no data are exchanged with LinkedIn on our Website.
Our Website also links to the Website of Twitter, operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, U.S.A. or, if you reside in the EU, Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland. Otherwise no data are exchanged with Twitter on our Website.
III. Data processing when visiting the LinkedIn Page https://www.linkedin.com/company/robincapital
We use the technical platform and information services of LinkedIn, operated by LinkedIn Corp, 1000 W Maude Ave, Sunnyvale, CA, 94085-2810, USA, or, if you reside in the EU, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
We would like to point out that you use the LinkedIn service offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. share, like). Alternatively, you can also access the information offered via LinkedIn on our website at https://www.linkedin.com/company/robincapital.
The data collected about you when using the service is processed by LinkedIn Ireland Unlimited Company and may be transferred to countries outside the European Union. This is, among other things, your IP address, the proxy server used, your operating system, your web browser and installed add-ons, device ID and functions, cookie IDs and/or ISP, your mobile provider and your location.
This data is associated with your LinkedIn account data or LinkedIn profile. We have no influence on the type and scope of the data processed by LinkedIn, the way it is processed and used, or the transfer of this data to third parties. You can find information about which data is processed by LinkedIn and for what purposes in the LinkedIn data protection declaration (https://www.linkedin.com/legal/privacy-policy) as well as about the possibility of viewing your own data at LinkedIn (https://www.linkedin.com/legal/privacy-policy#choices). Furthermore, you have the option of downloading your account data: https://www.linkedin.com/help/linkedin/answer/50191 We, as the provider of the information service, also collect and process data from your use of our service.
Options to restrict the processing of your data are available in the general settings of your LinkedIn account. In addition, for mobile devices (smartphones, tablet computers), you can restrict LinkedIn's access to contact and calendar data, photos, location data, etc. in the settings options there. However, this depends on the operating system used. Further information on these points is available on the following LinkedIn support page: https://www.linkedin.com/legal/privacy-policy#choices
IV. Data processing when visiting the Twitter Page https://twitter.com/robincapital_
We use the technical platform and services of Twitter, operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, U.S.A. or, if you reside in the EU, Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland.
We would like to point out that you use the Twitter short message service offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. share, like). Alternatively, you can also access the information offered via Twiiter on our website at https://twitter.com/robincapital_.
The data collected about you when using the service is processed by Twitter Inc. and may be transferred to countries outside the European Union. This includes, among other things, your IP address, the application used, information about the terminal device you are using (including device ID and application ID), information of accessed websites, your location and your mobile provider.
This data is assigned to the data of your Twitter account or your Twitter profile. We have no influence on the type and scope of the data processed by Twitter, the way it is processed and used, or the transfer of this data to third parties. You can find information about which data is processed by Twitter and for what purposes in Twitter's data protection declaration (https://twitter.com/privacy?lang=en) and about the possibility of viewing your own data on Twitter (https://help.twitter.com/en/managing- your-account/accessing-your-twitter-data). Furthermore, you have the option of requesting information via the Twitter data protection form or the archive requirements: https://help.twitter.com/en/forms/privacy https://help.twitter.com/en/managing-your- account/how-to-download-your-twitter-archive. We, as the provider of the information service, also collect and process data from your use of our short message service.
You have options to restrict the processing of your data in the general settings of your Twitter account and under the item "Privacy and security". In addition, you can restrict Twitter's access to contact and calendar data, photos, location data, etc. on mobile devices (smartphones, tablet computers) in the settings options there. However, this depends on the operating system used. Further information on these points is available on the following Twitter support pages: https://help.twitter.com/en/safety-and- security/twitter-privacy-settings.
October 2022