Privacy Policy - Alpha Ordinatum GmbH
Alpha Ordinatum, Kapitalverwaltungsgesellschaft, Alternative Investmentfonds, Publikums AIF
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Privacy Policy

Privacy Policy

Privacy Policy

As of December 2024


Table of contents

  1. Identity and contact details of the data controller
  2. Contact details of the data protection officer
  3. General information on data processing
  4. Rights of the data subject
  5. Data Processing when loading the website
  6. Contact via Email
  7. Contact form
  8. Hosting
  9. Usage of Plugins

 

  1. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

Alpha Ordinatum GmbH
Harrlachweg 1
68163 Mannheim
Deutschland

+49 (0) 621 | 490812-0

info@alpha-ordinatum.de
https://alpha-ordinatum.de</a

 

  1. Contact details of the data protection officer

The designated data protection officer is:

Alpha Ordinatum GmbH
Data Protection Officer
Harrlachweg 1
68163 Mannheim

Tel.: +49 621 490812-0
E-Mail: datenschutz@alpha-ordinatum.de
www.alpha-ordinatum.de

 

III. General information on data processing

  1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

  1. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (1) (a) General Data Protection Regulation (GDPR) serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) GDPR will serve as the legal basis for the processing of data.

  1. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfiling the respective contract.

 

  1. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

  1. Right of access (Art. 15 GDPR)

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

      • Purposes of processing
      • Categories of personal data being processed.
      • Recipients or categories of recipients to whom the personal data have been or will be disclosed.
      • Planned storage period or the criteria for determining this period
      • The existence of the rights of rectification, erasure or restriction or opposition.
      • The existence of the right to lodge a complaint with a supervisory authority.
      • If applicable, origin of the data (if collected from a third party).
      • If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
      • If applicable, transfer of personal data to a third country or international organization.
  1. Right to rectification (Art. 16 GDPR)

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay

  1. Right to the restriction of processing (Art. 18 GDPR)

You may request the restriction of the processing of your personal data under the following conditions:

      • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
      • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
      • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
      • If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data – apart from its storage – may only be processed 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 important 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.

  1. Right to erasure („Right to be forgotten“) (Art. 17 GDPR)

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

      • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
      • You withdraw your consent on which the processing is based pursuant to Article 6 (1)(a) or Article 9 (2)(a) GDPR and where there is no other legal basis for processing the data.
      • You object to the processing of the data pursuant to Art. 21 (1) GDPR and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
      • Your personal data has been processed unlawfully.
      • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
      • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Exceptions:

The right to deletion does not exist if the processing is necessary

      • to exercise the right to freedom of speech and information;
      • to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
  • for reasons of public interest in the area of public health in accordance with points (h) and (i) of Art 9(2) as well as Art 9(3) GDPR;
      • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes in accordance with Art 89(1) GDPR.
      • to enforce, exercise or defend legal claims.
  1. Right to information

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

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

  1. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

  • the processing is based on your consent (Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR ) or necessary for the performance of a contract (Art. 6 (1) (b) GDPR)
  • processing is carried out through automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the 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.

  1. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) GDPR; this also applies to profiling based on these provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates 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 relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

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

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right to object in connection with the use of information society services by means of automated procedures using technical specifications.

  1. Right to withdraw consent

You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

  1. Automated decision-making 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 shall not apply, if the decision:

  1. is necessary for entering into, or performance of, a contract between you and the controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. is based on your explicit consent.

These decisions shall not be based on special categories of personal data referred to in Art. 9(1) GDPR, unless point (a) or (g) of Art. 9(2) GDPR applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

In the cases referred to in points 1) and 3), the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

  1. 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 habitual residence, place of work or 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 Art. 78 GDPR.

  1. Data Processing when loading the website
  2. Description and scope of data processing

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

The following data is collected:

      • Browser type and version
      • Used operating system
      • Referrer URL
      • Hostname of the accessing computer
      • Time and date of access
      • IP address of the user’s device

This data is stored in the log files of our system. A storage of these data together with other data of the user is not taking place.

  1. Purpose of data processing

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

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

  1. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is our legitimate interest Art. 6 (1) (f) GDPR.

  1. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data listed under 1. for the provision of the website is accomplished.

If the data listed under 1. is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are alienated so that an assignment of the calling client is not possible.

  1. Exercising your rights

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. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.

  1. Contact via Email
  2. Description and scope of data processing

You can contact us via the email address provided on our website (info@alpha-ordinatum.de). In this case the personal data of the user transmitted with the email will be stored.

  1. Purpose of data processing

The data will be used exclusively for the processing of the conversation.

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

  1. Legal basis for data processing

If the user has given their consent, Art. 6 (1) (1) (a) (GDPR) serves as the legal basis for the processing of the data.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) (f) GDPR. Our legitimate interest is to optimally answer your request that you send by e-mail.

If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

  1. Duration of storage

The data will be deleted as soon as it is no longer necessary 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 ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved and provided that there are no legal obligations for data retention.

The additional personal data collected during the sending process (technical data) will be deleted after a period of seven days at the latest.

  1. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time. In this case, the conversation cannot be continued.

If you have given your consent to the processing of your data, you can withdraw it at any time. Such a revocation affects the permissibility of the processing of your personal data after you have expressed it to us. You can inform us of your withdrawal of consent using the following contact details: Alpha Ordinatum GmbH, Harrlachweg 1, 68163 Mannheim, datenschutz@alpha-ordinatum.de, see also section II. of this Privacy Policy.

In this case, all personal data stored while establishing contact will be deleted in accordance with the right to deletion in section IV. 4.

 

VII. Contact form

  1. Description and scope of data processing

A Contact form is available on our website, which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message the following data will also be stored:

      • Email address
      • Last name
      • First name
      • IP address of the user’s device
      • Date and time of contact
      • Subject, Message

We collect your consent for the processing of personal data through our contact form and link to our privacy policy.

  1. Purpose of data processing

The processing of the personal data from the input mask as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems. Please see more information under section IX. of this privacy policy.

  1. Legal basis for data processing

The legal basis for the processing of personal data is consent, Art. 6 (1) (a) GDPR.

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

  1. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified and provided that there are no legal obligations for data retention.

The additional personal data collected during the sending process (technical data) will be deleted after a period of seven days at the latest.

  1. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time.

If the user contacts us via the input mask in the contact form, the user can object to the storage of his or her personal data at any time. In this case, the conversation cannot be continued.

If you have given your consent to the processing of your data, you can withdraw it at any time. Such a revocation affects the permissibility of the processing of your personal data after you have expressed it to us. You can inform us of your withdrawal of consent using the following contact details: Alpha Ordinatum GmbH, Harrlachweg 1, 68163 Mannheim, datenschutz@alpha-ordinatum.de, see also under section II. of this Privacy Policy.

In this case, all personal data stored while establishing contact will be deleted in accordance with the right to deletion in section IV. 4.

 

VIII. Hosting

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

Our service provider is:

STRATO AG, Otto-Ostrowski-Strasse 7

10249 Berlin, Germany

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

      • Browser type and version
      • Used operating system
      • Referrer URL
      • Hostname of the accessing computer
      • Time and date of the server request
      • IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded. For more information see Section V. Data Processing when loading the website of this privacy policy.

The server of the website is geographically located in Germany.

  1. Usage of Plugins

We use various service providers to deliver the service we offer through the app.

Generally, where such services are essential to providing the basic service offered by the website, we have a legitimate interest in sharing your data with the relevant service providers in order to provide the relevant website service.

Where such services are required for additional services, enhanced functionalities, or additional purposes, your personal data will only be transferred to service providers if you provide consent.

Use of Contact Form 7

  1. Scope of processing of personal data

We use the WordPress plugin Contact Form 7 of RockLobster LLC, Sakai 810-0001 Fukuoka Prefecture Chuo-ku Tenjin 1-chome 8-1, Fukuoka City Hall, Japan (Hereinafter referred to as RockLobster) for the administration of contact forms on our online presence. The data entered in the form will be transferred by email. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular the IP address and the operating system). Data can be transferred to RockLobster servers in Japan. With regard to Japan, there is a European Union adequacy decision. You can find it here:
https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=OJ:L:2019:076:TOC
Further information about the collection and storage of data by Contact Form 7 can be found here:
https://contactform7.com/privacy-policy/

  1. Purpose of data processing

The use of the Contact Form 7 Plugins serves the improvement of the user friendliness of our online presence. We use this plug-in to easily create, integrate and present contact forms in an appealing way.

  1. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) GDPR.

  1. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

  1. Possibility of revocation of consent and removal

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

Furthermore, you can prevent Contact Form 7 from collecting and processing your personal data by preventing the storage of third-party cookies on your computer (for further visits to the website), by using the „Do Not Track“ feature of a supporting browser, by disabling the execution of script code in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. For more information about opting out of Contact Form 7 and opting out of its use, please visit:
https://contactform7.com/privacy-policy/

Use of WordPress Captcha

  1. Scope of the processing of personal data
    We use WordPress Captcha, a plugin designed to prevent spam and secure forms on our WordPress website, provided by Forge12 Interactive GmbH, Josefstraße 37, 78166 Donaueschingen, Germany. This plugin ensures that our contact form is completed by real users and that automated spam requests are blocked.
  2. Purpose of data processing
    The processing of personal data by WordPress Captcha is carried out to protect our website from automated spam requests and to ensure that only legitimate users have access to our forms.
  3. Legal basis for the processing of personal data
    The processing of personal data by WordPress Captcha is based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR. Our legitimate interest lies in the security and integrity of our website, as well as protection against misuse by spam and bots.
  4. Duration of storage
    The personal data collected by WordPress Captcha is only stored for as long as necessary to protect our website from spam requests and ensure its secure operation, and for as long as our legitimate interest in retaining the data persists. Once the purpose of data collection is fulfilled or our legitimate interest no longer exists, the data will be securely deleted or anonymized, unless legal retention obligations apply.
  5. Exercising your rights
    You have the right to object to the processing of your personal data by WordPress Captcha at any time. Additionally, you can prevent the collection and processing of your personal data by cookies by disabling the storage of third-party cookies in your browser settings. For more information about opting out of it and opting out of its use, please visit: Forge12 Interactive GmbH: https://www.forge12.com/en/privacy-policy/

Use of the SiteGuard

  1. Scope of the processing of personal data
    We use the SiteGuard WP Plugin, a WordPress plugin that provides additional security features, developed and provided by EG Secure Solutions, Tokyo, Japan. This plugin helps us enhance the security of our website by offering features such as login protection, two-factor authentication, and brute force attack prevention.
  2. Purpose of data processing
    The processing of personal data through the SiteGuard WP Plugin is carried out for the purpose of securing our website against unauthorized access and potential attacks. This includes processing security-related data such as users‘ IP addresses to prevent unauthorized access and abuse.
  3. Legal basis for the processing of personal data
    The processing of personal data through the SiteGuard WP Plugin is based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR. Our legitimate interest lies in ensuring the integrity and security of our website and protecting it from attacks and misuse.
  4. Duration of storage
    The personal data collected by the SiteGuard WP Plugin, such as IP addresses, is only stored for as long as necessary to secure our website and for as long as our legitimate interest in retaining the data persists. Once the purpose is fulfilled or our legitimate interest no longer exists, the data will be securely deleted or anonymized, unless legal retention obligations apply.
  5. Exercising your rights
    You can prevent the collection and processing of your personal data by the SiteGuard WP Plugin by blocking third-party cookies in your browser, using the „Do Not Track“ feature of a supported browser, or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. For more information about opting out of it and opting out of its use, please visit: https://www.eg-secure.co.jp/privacy

Use of Wordfence Security

  1. Scope of the processing of personal data
    We use Wordfence Security, a security plugin for WordPress websites, provided by Defiant Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA. This plugin protects our website from threats such as malware and unauthorized access by processing security-related data like IP addresses and implementing measures such as firewalls and malware scans.
  2. Purpose of data processing
    The processing of personal data through Wordfence Security is carried out to secure our website against cyberattacks, unauthorized access, and malware infections. It processes security-related data, such as visitors‘ IP addresses and suspicious activity, to detect and mitigate potential threats.
  3. Legal basis for the processing of personal data
    The processing of personal data through Wordfence Security is based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR. Our legitimate interest lies in ensuring the security of our website and protecting it from cyberattacks and misuse by third parties.
  4. Duration of storage
    The personal data collected by Wordfence Security, such as IP addresses, is only stored for as long as necessary to secure our website and for as long as our legitimate interest in retaining the data persists. Once the purpose is fulfilled or our legitimate interest no longer exists, the data will be securely deleted or anonymized, unless legal retention obligations apply.
  5. Exercising your rights
    You can prevent the collection and processing of your personal data by Wordfence Security by disabling the storage of third-party cookies on your computer, using the „Do Not Track“ feature of a supporting browser, or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. . For more information about opting out of it and opting out of its use, please visit: https://www.wordfence.com/privacy-policy/

This privacy policy has been created with the assistance of DataGuard.