1. Privacy Policy

Thank you very much for your interest in our company. Data protection is extremely important to the management of Empira AG. Personal data, which includes a data subject’s name, address, email address, or telephone number, is always processed in accordance with the Swiss Federal Act on Data Protection (FADP), the EU General Data Protection Regulation (GDPR), and other country-specific data protection provisions applicable to Empira AG. The purpose of this Privacy Policy is to inform members of the public about the nature, scope, and purpose of the personal data that we collect, use and process. This Privacy Policy also informs data subjects about their rights in this regard. We recommend that you regularly check the legal notices and Privacy Policy on our online services, which we strive to keep constantly up to date.
We process the personal data that is collected when you use our online services or that you provide yourself (e.g. when subscribing to a newsletter or submitting a job application).
As the data controller, Empira AG has implemented technical and organizational measures to ensure the fullest protection for the personal data processed via this website. Nevertheless, internet-based data transmission has inherent security vulnerabilities, which means that absolute protection cannot be guaranteed. For this reason, every data subject is free to communicate their personal data to us by alternative means, e.g. by post.

2. Terminology

The terms used in this Empira AG Privacy Policy are based on those used by EU legislators in the General Data Protection Regulation (GDPR).

3. Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation (GDPR), other data protection laws that apply in member states of the European Union and other data protection provisions is:
Empira AG
Gubelstrasse 32
6300 Zug
Schweiz
Tel: +41 41 728 75 75
Email: info@empira-invest.com
Website: www.empira-invest.com

A) Name and address of the data protection officer:
Name: Gerd Büttner | my-dsb.com
Address: Neue Mainzer Straße 6-10, 60311 Frankfurt, Deutschland
Email: Datenschutzbeauftragter@empira-invest.com

B) Representative in the EU:
Name: Gerd Büttner | my-dsb.com
Address: Neue Mainzer Straße 6-10, 60311 Frankfurt, Deutschland
Email: Datenschutzbeauftragter@empira-invest.com

4. Data collection

The data processing on this website is carried out by the website operator. You can find contact details for the website operator in section “3. Name and address of the data controller”.
In some cases your data is collected because you provide it to us, for example if you submit a newsletter subscription form or send us a job application.
Other data is captured by our IT systems when you visit the website, either automatically or with your consent. This is mainly technical data (e.g., your internet browser, your operating system, or the time that you accessed a page). This data is captured automatically as soon as you access the website.
Some of the data is collected in the interests of ensuring the error-free provision of the website. Other data may be used to analyze your user behavior.

5. Our cookie policy

A) General information about the use of cookies
Our website uses cookies, small database entries that are saved to your device and stored in your browser. They help to make our services more user-friendly, effective, and secure. We use both temporary session cookies, which are automatically deleted when you close your browser, and persistent cookies.
You can choose whether or not to allow cookies. You can change your preference in your browser settings at any time. You have the choice between accepting cookies, being informed when cookies are set, or rejecting all cookies. If you opt to reject all cookies, it is possible that you might not be able to use our services in full. You can make individual adjustments in your cookie settings.
In using cookies, it is important to distinguish between essential cookies and those used for other purposes (e.g., for measuring visitor numbers or for advertising purposes).

B) Cookies that are essential for use of the website
We use session cookies on our website that are essential for using the site. These include cookies that enable us to recognize you again when you visit the site within a single session. These session cookies help to ensure that our services are used securely.

C) Cookies that we use based on your consent
Below is a list of the cookies that we use on the basis of the consent you grant when you first began using the website. You can make individual adjustments in your cookie settings at any time. These cookies are used to capture the user behavior of visitors to our website.
Cookies that we use for tracking purposes
Using tracking cookies enables us to recognize users when they return to our website on subsequent visits, and to attribute patterns of user behavior to an internally assigned pseudonym. This means we can record repeat visits to our website and meaningfully analyze them.
Collection of general data and information
Every time the Empira AG website is accessed by an individual or an automated system, the site records a series of items of general data and information. This general data and information is stored in the server’s logfiles. This information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website and its advertising, (3)to ensure the long-term functioning of our IT systems and the technology behind our website, and (4) provide criminal investigators with the necessary information in the event of cyber-attacks.
Empira AG evaluates the data and information collected in this way for statistical purposes and with the aim of improving data protection and data security at our company, and ultimately to achieve an optimum level of protection for the personal data that we process. The anonymized data in the server logfiles is stored separately from all personal data entered by a data subject.

D) Cookie-Einwilligung mit Usercentrics
Our website uses the cookie consent technology from Usercentrics to obtain your consent to the storing of certain cookies on your device and to documenting this in accordance with data protection principles. The provider of this technology is Usercentrics GmbH, Sendlinger Strasse 7, 80331 Munich. When you enter our website, a connection to Usercentrics’ servers is established in order to obtain your consent and other declarations in relation to the use of cookies. Usercentrics subsequently stores a cookie in your browser so that it can assign your consent and/or revocation. The data entered in this way will be stored until you ask us to delete it, you delete the Usercentrics cookie yourself, or the purpose of the data storage ceases to apply. Statutory retention periods remain unaffected. We use Usercentrics to obtain consent for the use of cookies required by law. Lawfulness of processing is based on Art. 6 para. 1 (c) GDPR.

6. The following specific tracking cookies are used

A) Google Analytics
This website uses functions of the Google Analytics web analysis service, provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US.
Google Analytics uses cookies.
The storage of Google Analytics cookies and use of these analytical tools is based on Art. 6, para. 1 (a) GDPR (consent) and Art. 6, para. 1 (f) GDPR (legitimate interest). We use this web analysis service to analyze the use of our website so that we can better understand how visitors engage with it and make it even more intuitive. You can withdraw your consent at any time via our consent management tool.
IP anonymization:
We have enabled IP anonymization on our website. Consequently, Google truncates IP addresses of users in EU or EEA countries before transmitting them to the US. In exceptional cases only, the full IP address may be transmitted to a server in the US and then truncated there. Google uses this information on behalf of the website operator to evaluate your use of the website, to compile reports on website activities, and to provide the website operator with other services connected to use of the website and the internet. Google does not combine the IP address transmitted by your browser through Google Analytics services with any other data held by Google.
Browser Plugin:
You can prevent the storage of cookies via the settings in your browser software; however, please note that by doing so you may not be able to make full use of all the functions of this website. You can also prevent Google collecting the data generated by the cookie and relating it to your use of the website (including your IP address) and Google’s processing of this data by downloading and installing the browser plugin which you can find here: https://tools.google.com/dlpage/gaoptout?hl=en.
Opting out of data collection:
You can prevent the collection of your data by Google Analytics via the link below. This will set an opt-out cookie that prevents the collection of your data on future visits to this website: Disable Google Analytics.
You can find more information on the use of user data at Google Analytics in this data privacy information from Google: https://support.google.com/analytics/answer/6004245?hl=en.
Demographics and Interests service from Google Analytics:
This website uses the Demographics and Interests function provided by Google Analytics. This enables reports to be produced containing details of the age, gender, and interests of website users. This data originates from Google’s interest-based advertising data and visitor data from third-party providers. This data cannot be linked to any specific individuals. You can disable this function at any time in the ad settings of your Google account or opt out of all collection of your data by Google Analytics as described in “Opting out of data collection” above.
Retention period:
User-level and event-level data held by Google that is associated with cookies, user identifiers (e.g., user ID), or advertising identifiers (e.g., DoubleClick cookies, Android’s advertising ID) is anonymized and/or deleted after 14 months. You can find details here: https://support.google.com/analytics/answer/7667196?hl=en.
B) Google Tag Manager
This website uses functions of the Google Tag Manager web service. The provider is Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).
Tag Manager makes it easier to implement tracking and statistics tools on our website. This service enables website tags to be managed via an interface. Tags are small elements of code used on a website for purposes that include measuring traffic and user behavior, capturing the impact of online advertising and social media channels, remarketing and focusing on specific target audiences, and testing and optimizing the website. The use of Google Tag Manager makes using our website faster and more efficient, as managing the correct tags speeds up the site. If Google Tag Manager is disabled at domain or cookie level, it remains so for all tracking tags implemented via Google Tag Manager.
No information about visitors is stored or shared when using Google Tag Manager.
The use of this analytical tool is based on Art. 6, para. 1 (a) GDPR (consent) and Art. 6, para. 1 (f) GDPR (legitimate interest).
Your personal data is transmitted to the US, where data protection is not equivalent to EU standards. You are therefore exposed to the risk that governmental bodies might access this data.
You can find details here:
https://support.google.com/tagmanager/answer/9323295?hl=en.
C) MapBox
Our website connects via an interface to the online map provider Mapbox. This enables us to display interactive maps directly on our website, making it convenient for you to use the map functions. The mapping service is provided by Mapbox, Inc., 740 15th St NW, Suite 500, Washington DC 20005, USA.
In order to use the Mapbox functionalities, the following data must be collected and retained:
IP address, device and browser information, operating system, content of the query, date and time of the query, usage data, location data (when using a mobile application).
The legal basis for the processing of your personal data is your consent pursuant to Art. 6, para. 1 (a) GDPR.
As personal data is transmitted to the US, additional protections are required to ensure that data protection meets GDPR standards. To ensure this, Mapbox uses standard contractual clauses within the meaning of Art. 46, para. 2 (c) GDPR. These clauses oblige data recipients in the US to process the data in accordance with European standards of protection.
You can find more information about the management of user data in Mapbox’s Privacy Policies: https://www.mapbox.com/legal/privacy.

7. Routine deletion and blocking of personal data

We only process and retain your personal data as long as it is required for the purpose of retention or for the period laid down by European or other legislators in laws or regulations to which the data controller is subject (e.g. retention periods under tax or commercial law).
Once the purpose of retention ceases to apply or a retention period laid down by a European or other applicable legislator expires, the personal data is routinely blocked or deleted in accordance with the law.
General information on the legal basis for data processing by this website:
If you have consented to data processing, we process your personal data on the basis of Art. 6, para. 1 (a) GDPR or Art. 9, para. 2 (a) GDPR where special categories of personal data within the meaning of Art. 9, para. 1 apply. If you have expressly consented to the transmission of your personal data to a third country, data is also processed on the basis of Art. 49, para. 1 (a) GDPR. You can withdraw your consent at any time. If your data is required for the performance of a contract or to take steps prior to entering into a contract, we process your data on the basis of Art. 6, para. 1 (b) GDPR. Where we process your data for compliance with a legal obligation, we do so on the basis of Art. 6, para. 1 (a) GDPR. Data may also be processed on the basis of our legitimate interest pursuant to Art. 6, para. 1 (f) GDPR.

8. Rights of data subjects

Every data subject has the following rights:

The right to be informed (Art. 15 GDPR)
The right to rectification (Art. 16 GDPR)
The right to erasure (right to be forgotten) (Art. 17 GDPR)
The right to restrict processing (Art. 18 GDPR)
The right to data portability (Art. 20 GDPR)
You can opt out of the processing of personal data for advertising purposes, including the analysis of customer data for advertising purposes, at any time and without giving a reason
Data subjects also have a general right to object (see Art. 21, para. 1 GDPR), in which case a reason for such an opt-out must be given. Where data is processed on the basis of your consent, you can withdraw your consent with future effect at any time

The simplest way to exercise your rights as a data subject is to write to info@empira-invest.com. You also have the right to lodge a complaint with a supervisory body with responsibility for data protection.
Right to withdraw consent under data protection law:
Under European legislation, every data subject has the right to withdraw their consent to the processing of their personal data with future effect, at any time and without giving a reason. The best way to do this is to write to info@empira-invest.com.

9. Data protection in relation to job applications and related processes

The data controller collects and processes the personal data of job applicants for the purposes of the application process. The legal basis for this processing is Art. 6, para. 1 (b) EU/GDPR or Art. 6 GDPR (Switzerland) and, if you have provided your consent, Art. 6, para. 1 (a) GDPR. If the data controller enters into an employment contract with an applicant, the transmitted data will be retained for the purposes of administering the employment relationship in accordance with the statutory provisions. If the data controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted depending on country-specific regulations after the notification of the rejection decision, unless such deletion conflicts with any other legitimate interests or legal bases (e.g., the consent of the data subject).

Applications are processed centrally within the Empira Group (Empira Asset Management, Leipzig) and forwarded to our service provider Personio. This forwarding is carried out in the interest of secure, fast, and efficient processing of your application. We have entered into a data processing agreement with the service providers. This is a contract required by data protection law, ensuring that the provider processes the personal data of our website visitors only according to our instructions and in compliance with the data protection provisions of the DSG and the GDPR.

10. Retention period for personal data

If no other retention period is specified in this Privacy Policy, we will retain your personal data until such time as the purpose of data processing ceases to apply. If you make a valid request for deletion or withdraw your consent for data processing, your data will be deleted unless we have other legal grounds for retaining your personal data (e.g. retention periods under tax or commercial law); in the latter case the data will be deleted once that reason ceases to apply.

11. Provision of personal data as a legal or contractual requirement; requirement for conclusion of a contract; obligation of data subject to provide personal data; possible consequences of non-provision of this data

Please note that the provision of personal data may in some instances be required by law (e.g. tax regulations) or under a contract (e.g. details of the party to the contract). When entering into a contract, it may sometimes be necessary for a data subject to provide us with personal data that we subsequently need to process.

12. Salesforce Marketing Cloud Account Engagement newsletter service

(Salesforce, Inc. Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, US)
Your consent to receiving the newsletter is documented internally by Empira and communicated to the newsletter service Salesforce Marketing Cloud Account Engagement. In connection with the Salesforce Marketing Cloud Account Engagement service, we may transmit data outside the EU and EEA. In order to use this service, we require your consent (which you are free to withdraw at any time).
The potential risks associated with the data transmission cannot be excluded. In particular, it is possible that your data could be subject to inspection and monitoring by the US authorities that go beyond the actual purpose and that there may be no effective legal remedy against these official inquiries that would enable you to enforce and permanently assert your data protection rights.

13. Privacy Policy of Empira Asset Management GmbH

You can access and print out the current privacy policy here.

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