Data protection information
We take data protection seriously and hereby inform you how we process your data and what claims and rights you are entitled to under data protection regulations. Valid as of May 25, 2018.
Part 1: Data protection information about our data processing in accordance with Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR).
1. entity responsible for data processing and contact details
Responsible entity in terms of data protection law Swiss Life Kapitalverwaltungsgesellschaft mbH Darmstädter Landstraße 125 60598 Frankfurt Tel: +49 69 2648642 123 Fax: +49 69 2648642 499 Contact details of the data protection officer of Swiss Life KVG: HEC Harald Eul Consulting GmbH Harald Eul Auf der Höhe 34 50321 Brühl Phone +49 2232 200 879 dsb-swisslifekvg@he-c.de
2. purposes and legal basis on which we process your data
Personal data in the sense of the Federal Data Protection Act (BDSG) is individual information about personal and factual circumstances of a specific or identifiable natural person. This includes, for example, name, address, date of birth, profession, bank details or information about personal financial circumstances. All of this data is subject to special protection in accordance with the BDSG, which we ensure through technical and organizational measures. We process personal data in accordance with the provisions of the General Data Protection Regulation (DSGVO), the Federal Data Protection Act (BDSG) and other applicable data protection regulations (details below). Which data is processed in detail and how it is used depends largely on the services requested or agreed in each case. Further details or additions to the purposes of data processing can be found in the respective contractual documents, forms, a declaration of consent and/or other information provided to you (e.g. in the context of using our website or our terms and conditions). In addition, this data protection information may be updated from time to time, as you can see from our website www.haagschehofkantoor.nl. Each time you access the Internet pages of Swiss Life Kapitalverwaltungsgesellschaft mbH, information transmitted by your browser is automatically stored temporarily. The log file created records the browser type/version, operating system used, name and URL of the file accessed, referrer URL (the page previously visited), volume of data transferred, host name of the accessing computer (IP address) and the date and time of the server request. It is therefore not possible to draw conclusions about specific persons. A combination of this data with other data sources is not made, the data is also deleted after a statistical analysis. The storage and processing of this data is solely for the purpose of system security as well as the optimization of the Internet offer. Therefore, we do not require any personal data from you for a visit to our website. You can move absolutely anonymously in the sense of the BDSG.
2.1 Purposes for the fulfillment of a contract or pre-contractual measures (Art. 6 para. 1 b DSGVO).
Personal data is processed for the performance of our contracts with you and the execution of your orders, as well as for the performance of measures and activities in the context of pre-contractual relations, e.g. with interested parties. In particular, the processing thus serves the provision of real estate services, such as
the mediation
the letting
the sale
the purchase
of real estate according to your orders and wishes and include the services, measures and activities necessary for this. These essentially include contract-related communication with you, the verifiability of transactions, orders and other agreements, as well as for quality control through appropriate documentation, goodwill procedures, measures for the control and optimization of business processes and for the fulfillment of general due diligence obligations, management and control by affiliated companies (e.g. parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax assessment of operational services, risk management, assertion of legal claims and defense in the event of legal disputes; ensuring IT security (e.g. system or plausibility tests) and general security, including building and facility security, ensuring and exercising domiciliary rights (e.g., through access controls); ensuring the integrity, authenticity and availability of data, prevention and investigation of criminal acts; control by supervisory bodies or control authorities (e.g., auditing).
2.2. purposes in the context of a legitimate interest of us or third parties (Art. 6 para. 1 f DSGVO).
Beyond the actual performance of the contract or preliminary contract, we may process your data if it is necessary to protect legitimate interests of us or third parties, in particular for purposes:
of advertising or market and opinion research, insofar as you have not objected to the use of your data;
obtaining information and exchanging data with credit agencies, insofar as this exceeds our economic risk;
the testing and optimization of demand analysis procedures;
the further development of services and products as well as existing systems and processes;
the disclosure of personal data as part of due diligence in company sale negotiations;
for comparison with European and international anti-terrorism lists, insofar as this goes beyond the legal obligations;
the enrichment of our data, including through the use or research of publicly available data;
statistical evaluations or market analysis;
benchmarking;
the assertion of legal claims and defense in legal disputes that are not directly related to the contractual relationship;
the limited storage of data, if deletion is not possible or only possible with disproportionate effort due to the special nature of the storage;
the development of scoring systems or automated decision-making processes;
the prevention and investigation of criminal offences, insofar as not exclusively for the fulfillment of legal requirements;
building and facility security (e.g. through access controls and video surveillance), insofar as this goes beyond general due diligence requirements;
internal and external investigations, security checks;
the possible listening in or recording of telephone conversations for quality control and training purposes;
Obtaining and maintaining certifications under private or governmental law;
safeguarding and exercising house rights by means of appropriate measures such as video surveillance for the protection of our customers and employees as well as for securing evidence in the event of criminal offences and their prevention.
2.3 Purposes within the scope of your consent (Art. 6 para. 1 a DSGVO).
Processing of your personal data for certain purposes (e.g. use of your e-mail address for marketing purposes) may also be based on your consent. As a rule, you can revoke this at any time. This also applies to the revocation of declarations of consent given to us before the DSGVO came into force, i.e. before May 25, 2018. You will be informed separately about the purposes and consequences of revoking or not granting consent in the relevant text of the consent. In principle, the revocation of consent only takes effect for the future. Processing that took place before the revocation is not affected by this and remains lawful.
2.4 Purposes for the fulfillment of legal requirements (Art. 6 para. 1 c DSGVO) or in the public interest (Art. 6 para. 1 e DSGVO).
Like anyone who participates in economic activity, we are subject to a variety of legal obligations. Primarily, these are legal requirements (e.g., commercial and tax laws), but also, where applicable, regulatory or other official requirements. The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and investigation of terrorist financing and asset-threatening crimes, comparisons with European and international anti-terrorist lists, the fulfillment of control and reporting obligations under tax law, and the archiving of data for data protection and data security purposes as well as audits by tax and other authorities. In addition, the disclosure of personal data may be necessary in the context of official/court measures for the purposes of gathering evidence, criminal prosecution or enforcement of civil claims.
3. the categories of data we process, insofar as we do not receive data directly from you, and their origin.
To the extent necessary for the provision of our services, we process personal data permissibly received from other companies or other third parties (e.g. credit agencies, address publishers). In addition, we process personal data that we have permissibly taken, received or acquired from publicly accessible sources (such as telephone directories, commercial and association registers, civil registers, debtor directories, land registers, the press, the Internet and other media) and may process. Relevant personal data categories may include in particular:
Personal data (name, date of birth, place of birth, nationality, marital status, profession/industry and comparable data)
Contact data (address, e-mail address, telephone number and comparable data)
Address data (registration data and comparable data)
Payment/coverage confirmation for bank and credit cards
Information about your financial situation (creditworthiness data including scoring, i.e. data for assessing economic risk)
Customer history
Data about your use of the telemedia offered by us (e.g., time of calling up our websites, apps or newsletters, pages/links clicked on by us or entries and comparable data)
Video data
4. recipients or categories of recipients of your data.
Within our company, those internal departments or organizational units receive your data that require it to fulfill our contractual and legal obligations or as part of the processing and implementation of our legitimate interest. Your data will only be passed on to external bodies in connection with
in connection with the processing of contracts
for the purpose of fulfilling legal requirements according to which we are obliged to provide information, report or pass on data or the passing on of data is in the public interest (cf. section 2.4);
to the extent that external service providers process data on our behalf as order processors or function transferees (e.g. external data centers, support/maintenance of EDP/IT applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data validation and/or -(e.g., data validation or plausibility check, data destruction, purchasing/procurement, customer administration, lettershops, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutions, printing companies or companies for data disposal, courier services, logistics);
on the basis of our legitimate interest or the legitimate interest of the third party for the purposes mentioned in section 2.2 (e.g. to authorities, credit agencies, debt collection, lawyers, courts, appraisers, affiliated companies and committees and supervisory bodies);
if you have given us your consent to transfer your data to third parties.
We will not pass on your data to third parties beyond this. If we commission service providers to process your data, they are subject to the same security standards as we are. In other cases, the recipients may only use the data for the purposes for which it was transmitted to them.
5. duration of the storage of your data
We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the processing of a contract. In addition, we are subject to various storage and documentation obligations, which result, among other things, from the German Commercial Code (HGB), the Broker and Property Developer Ordinance (MaBV) and the Fiscal Code (AO). The periods specified there for storage and documentation are up to ten years beyond the end of the business relationship or the pre-contractual legal relationship. Furthermore, special statutory provisions may require a longer retention period, such as the preservation of evidence within the scope of statutory limitation provisions. According to Sections 195 et seq. of the German Civil Code (BGB), the regular limitation period is three years; however, limitation periods of up to 30 years may also be applicable. If the data is no longer required for the fulfillment of contractual or legal obligations and rights, it is regularly deleted, unless its - temporary - further processing is necessary for the fulfillment of the purposes listed under section 2.2 due to an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if deletion is not possible or only possible with disproportionate effort due to the special nature of the storage and processing for other purposes is precluded by appropriate technical and organizational measures.
6. processing of your data in a third country or by an international organization.
A data transfer to entities in countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) is carried out if it should be necessary for the execution of an order/contract from or with you, it is required by law (e.g. fiscal reporting obligations), it is within the scope of a legitimate interest of us or a third party or you have given us your consent. In this context, the processing of your data in a third country may also take place in connection with the involvement of service providers as part of commissioned processing. If there is no EU Commission decision on an adequate level of data protection for the country in question, we will ensure that your rights and freedoms are adequately protected and guaranteed in accordance with EU data protection requirements by means of appropriate contracts. We will provide you with corresponding detailed information upon request. Information on the appropriate or adequate guarantees and on the possibility of obtaining a copy from you can be obtained from the company data protection officer upon request.
7. your data protection rights
Under certain conditions, you can assert your data protection rights against us
For example, you have the right to receive information from us about your data stored by us according to the rules of Art. 15 DSGVO (if necessary with restrictions according to § 34 BDSG).
Upon your request, we will correct the data stored about you in accordance with Art. 16 DSGVO if it is inaccurate or incorrect.
If you wish, we will delete your data in accordance with the principles of Art. 17 DSGVO, provided that other statutory regulations (e.g. statutory retention obligations or the restrictions under Section 35 BDSG) or an overriding interest on our part (e.g. for the defense of our rights and claims) do not prevent this.
Taking into account the requirements of Art. 18 DSGVO, you may request us to restrict the processing of your data.
Furthermore, you may object to the processing of your data pursuant to Art. 21 DSGVO, on the basis of which we must terminate the processing of your data. However, this right of objection only applies in the case of very special circumstances of your personal situation, whereby rights of our company may possibly conflict with your right of objection.
You also have the right to receive your data in a structured, common and machine-readable format under the conditions of Art. 20 DSGVO or to transfer it to a third party.
In addition, you have the right to revoke your consent to the processing of personal data at any time with effect for the future (see section 2.3).
Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 DSGVO). However, we recommend that you always first address a complaint to our data protection officer.
If possible, your requests about exercising your rights should be addressed in writing to the above address or directly to our Data Protection Officer.
8. scope of your obligations to provide us with your data
You only need to provide us with the data that is required for the establishment and performance of a business relationship or for a pre-contractual relationship with us, or which we are legally obliged to collect. Without this data, we will generally not be able to conclude or execute the contract. This may also refer to data required later in the course of the business relationship. If we request additional data from you, you will be informed separately of the voluntary nature of the information.
9. existence of automated decision-making in individual cases (including profiling).
We do not use any purely automated decision-making procedures pursuant to Article 22 DSGVO. If we do use such a procedure in individual cases in the future, we will inform you of this separately, insofar as this is required by law. Under certain circumstances, we may process your data in part with the aim of evaluating certain personal aspects (profiling). In order to be able to provide you with targeted information and advice on products, we may use evaluation tools. These enable needs-based product design, communication and advertising, including market and opinion research. Such procedures may also be used to assess your creditworthiness and credit standing and to combat money laundering and fraud. So-called “score value” may be used to assess your creditworthiness and credit standing. Scoring involves calculating the probability, using mathematical methods, that a customer will meet his or her payment obligations in accordance with the contract. Such score values thus support us, for example, in assessing creditworthiness, in decision-making in connection with product transactions, and in our risk management. The calculation is based on mathematically statistically recognized and proven methods and is carried out on the basis of your data, in particular income situation, expenses, existing liabilities, occupation, employer, length of employment, experience from the previous business relationship, contractual repayment of previous loans and information from credit agencies. Special categories of personal data according to Art. 9 DSGVO are not processed in this context.
Information about your right to object Art. 21 DSGVO 1. You have the right to object at any time to the processing of your data based on Art. 6 (1) f DSGVO (data processing based on a balance of interests) or Art. 6 (1) e DSGVO (data processing in the public interest) if there are grounds for doing so that arise from your particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. 2. we may also process your personal data in order to carry out direct advertising. If you do not wish to receive advertising, you have the right to object to this at any time; this also applies to profiling, insofar as it is associated with such direct advertising. We will observe this objection for the future. We will no longer process your data for direct marketing purposes if you object to processing for these purposes. The objection can be made without formalities and should preferably be addressed to werden an Swiss Life Kapitalverwaltungsgesellschaft mbH Darmstädter Landstraße 125 60598 Frankfurt
Part 2: Supplementary information on visiting the website
1. protocol data of the internet browser
When you visit our website, personal data is also processed. In order for the pages to be displayed in your browser, the IP address of the terminal device you are using must be processed. In addition, there is further information about the browser of your end device. Under data protection law, we are also obliged to guarantee the confidentiality and integrity of the personal data processed with our IT systems. For this purpose, the following data is logged
Date of access
Time of access
URL of the referring website
Retrieved file
Amount of data transferred
Browser type and version
Operating system
IP address
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Information about browser type and version used
Language and version of the browser software
The IP address is deleted from all systems used in connection with the operation of this website after 5 days at the latest. We can then no longer establish a personal reference from the remaining data. The data is also used to correct errors on the website. The legal basis for this data processing is Art. 6 para. 1 lit. f) DSGVO. Our legitimate interest is the operation of this website and thus the implementation of the protection goals of confidentiality, integrity and availability of the data.
2. contact option via the website
The website www.haagschehofkantoor.nl of Swiss Life Kapitalverwaltungsgesellschaft mbH contains information that enables rapid electronic contact with our company and direct communication with us, which also includes an e-mail address. There is also a contact form where the personal data collected is derived from the input mask used for this purpose. Such personal data transmitted on a voluntary basis by a data subject to the data controller shall be stored for the purposes of contacting the data subject by the brokers OTTO Immobilien GmbH and teamneunzehn.at Immobilienmanagement GmbH. The legal basis for this data processing is your voluntary consent pursuant to Art. 6 (1) a) DSGVO.
3. Cookies
General information on the use of cookies When you visit and use our website, cookies are stored on your computer. 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 accesses 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. The legal basis for data processing when using essential cookies is Art. 6 para. 1 p. 1 lit. f) DS-GVO, when using all other cookies the legal basis is your consent according to Art. 6 para. 1 p. 1 lit. a) DS-GVO. For more information on individual cookies, please see the information in the cookie banner on the website. You can revoke your consent at any time by calling up the cookie banner again. This can be done by clicking on the icon at the bottom left of the screen. To the extent that we do not process your data based on your explicit consent, your personal data will only be processed to the extent necessary to protect our legitimate interests or the legitimate interests of a third party and to the extent that this does not override your interests or fundamental rights and freedoms requiring the protection of personal data.
4. Google Maps
This website uses Google Maps (“Google Maps”), a mapping service provided by Google, Inc (“Google&rquo;) to display interactive maps.
For this purpose, Google collects your IP address, which may be transferred by Google to servers in the USA and stored there. In addition, Google may collect data about your use of Google Maps. Please note that we do not control the collection, storage and use of such data by Google and do not have access to the collected data. Please review Google's privacy policy prior to any use of Google Maps features. Google's privacy policy can be found at www.google.de/intl/en/policies/privacy/.
By using Google Maps on our website, you agree to Google's Terms of Use, which can be viewed at https://www.google.com/intl/en/help/terms_maps/.
If you do not agree to the collection of your data through the use of Google Maps by Google, you can prevent such data collection by completely deactivating the Google Maps service. To do this, JavaScript must be deactivated in the browser settings. However, Google Maps cannot then be used.
5. security and encryption
Swiss Life Kapitalverwaltungsgesellschaft mbH protects the customer data it collects by storing the data on password-protected servers secured by firewalls and by using encryption technology to protect it from unauthorized access. Data transmitted to us during the use of the website is transferred using SSL encryption technology. Even though we try to provide you with a secure environment for your data with these precautionary measures, no absolute security of your data can be guaranteed on the Internet. We therefore recommend that you take every possible precaution to protect your personal data while connected to the Internet. In particular, please ensure that you use strong passwords, adequate and up-to-date virus scanners, and a secure browser.
6. External links
Hyperlinks on our websites or advertising banners take you to websites of third-party companies that are subject to different data protection practices. Swiss Life Kapitalverwaltungsgesellschaft mbH does not adopt the content of these websites as its own and is not liable for them or for the data protection practices of other providers that can be reached via the hyperlinks on our websites.
Our privacy policy as well as the information on data protection regarding our data processing pursuant to Articles (Art.) 13, 14 and 21 DSGVO may change from time to time. We will publish all changes on this page. We provide older versions for you to view in an archive.