Data privacy notice

 

1. Scope of personal data processing
   We only collect and use personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services. The collection and use of the personal data of our users is normally only carried out with the user's consent. An exception applies in cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by statutory provisions.
2. Legal basis for the processing of personal data
   If we obtain the data subject’s consent for the processing of personal data, Art. 6(1)(a) of the EU General Data Protection Regulation (GDPR) applies as the legal basis for the processing of personal data. When processing the personal data required for the performance of a contract to which the data subject is a party, Art. 6(1)(b) GDPR applies as the legal basis. This also holds for processing necessary for the implementation of pre-contractual measures. If it is necessary to process personal data to fulfil a legal obligation to which our company is subject, Art. 6(1)(c) GDPR applies as the legal basis. In the event that the vital interests of the data subject or another natural person require personal data to be processed, Art. 6(1)(d) GDPR applies as the legal basis. If processing is necessary to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6(1)(f) GDPR applies as the legal basis for processing.
3. Data deletion and duration of storage
   The data subject’s personal data will be deleted or blocked as soon as the purpose for retaining the data no longer applies. Personal data may also be stored if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. The data shall also be blocked or deleted if a retention period prescribed by the aforementioned regulations lapses, unless there is a requirement for the data to be stored for a longer period for the purpose of concluding or performing a contract.

1. Description and scope of data processing
   a) Access to our web pages
   Every time one of our web pages is accessed, our system automatically collects data and information from the system of the computer accessing the web page.
   
   The following data is collected in this process:
   Browser type/version,
   operating system used,
   name and URL of the file accessed,
   referrer URL (the previously visited page),
   host name of the accessing computer (IP address),
   date and time of the server request.
   
   The data is also stored in our system log files. This data is not stored with other personal user data – provided that the login function below is not used.
   
   b) Use of the login function
   It is possible to log in to our login area using personalised access data. The login details for registration are provided by the user by entering an e-mail address twice and entering a password twice. Via the login area, the user has access to their account settings as well as an overview of their completed subscriptions and the option of starting a new subscription and ending a started subscription.
   
   The user remains logged in to the login area even after leaving our website, unless they actively log out.
   Each time you use the login area, we process the IP address and the time of access.
   
   
2. Legal basis for data processing
   The legal basis for the temporary storage of data and log files is Art. 6(1)(f) of the General Data Protection Regulation (GDPR). The legal basis for the processing of data within the login area (e.g. name, password and e-mail address) is Art. 6(1)(a) GDPR.
3. Purposes of data processing
   The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. To do this, the user’s IP address must be stored for the duration of the session. It is stored in log files to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our information technology systems. In addition, legitimate purposes include – in the case of voluntary use of the login function – the evaluation of access to the protected areas of our login area, the guarantee of its integrity as well as the prevention of misuse or other unauthorised use. The data will not be evaluated for marketing purposes in this context. In respect of these purposes, we have a legitimate interest in processing the data pursuant to Art. 6(1)(f) GDPR.
4. Duration of storage
   The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. If the data is collected for the provision of the website, it is no longer needed when the respective session has ended. If the data is stored in log files, it will be erased after a maximum of seven days. Longer storage periods are possible. In this case, the user’s IP addresses are erased or altered so that the accessing client can no longer be identified. After 3 years of inactivity, the personal login area and the associated data are automatically erased.
5. Objection and deletion options
   The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. Consequently, there is no option for the user to object.

1. Description and scope of data processing
   Through its website, Commerz Real Fund Management S.à.r.l. offers you the opportunity to obtain information on various questions relating to the European Long-term Investment Fund, klimaVest, or to contact the company. You have the option of contacting Commerz Real Fund Management S.à.r.l. via the contact form, by calling, agreeing to a callback or by (digitally) ordering information material. When making contact, data such as your name, e-mail address and telephone number is collected. We use the Eloqua service from Oracle Deutschland B.V. & Co. KG for collecting data for optimal customer communications, for determining user behaviour on our website, and for sending automated e-mails (e.g. confirmations of receipt). Further information on the Eloqua marketing tool can be found under point VIII. Web tracking – use of the Eloqua marketing tool. If you do not consent to receiving klimaVest advertising information when submitting the contact form, your data will be used only to process your request. However, if your request relates to the activities of Commerz Real AG or its subsidiaries, holding companies or companies acting as an agency of Commerz Real AG and this is necessary for the efficient processing of the request, your data may also be passed on to the relevant company.
2. Legal basis for data processing
   If consent has been obtained from the user, the legal basis for the processing of data is Art. 6(1)(a) of the General Data Protection Regulation (GDPR). The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6(1)(f) GDPR. If the intention of making contact is to conclude a contract, the additional legal basis for the processing is Art. 6(1)(b) GDPR.
3. Purpose of data processing
   Personal data from the input screen is solely used for the purpose of processing the contact, unless you have consented to receiving advertising information when submitting the contact form (see point V. Newsletter). If you contact us by e-mail or telephone, we will only store and process your data for as long as this is necessary and there is a legitimate interest in the processing of the data.
4. Duration of storage
   The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. This applies to the personal data from the input screen of the contact form and that sent by e-mail when the respective communication with the user has ended. Communication ends when circumstances indicate that the matter in question has been conclusively clarified.   
5. Objection and deletion options
   The user has the option of withdrawing their consent to the processing of personal data at any time. If the user contacts us by e-mail, they can object to the storage of their personal data at any time. In such a case, communication via e-mail cannot continue. In this case, all personal data stored in the contact-making process will be erased. 

1. Description and scope of data processing
   Commerz Real Fund Management S.à.r.l. offers you the opportunity to subscribe to shares in the klimaVest ELTIF via an online platform provided by Commerz Real Fund Management S.à.r.l. Commerz Real Fund Management S.à.r.l has commissioned CP Capital Pioneers GmbH to provide investment advice, brokerage and support in the execution of your subscription. For these purposes, the personal data required for this purpose is transmitted to CP Capital Pioneers GmbH via the platform. If applicable and specified by you, your BSW Verbraucher-Service Beamten-Selbsthilfewerk GmbH member number will also be forwarded to them. Further details can be found in the data privacy notices of Commerz Real Fund Management S.à.r.l. and the data privacy notices of CP Capital Pioneers GmbH.
2. Legal basis for data processing
   The legal basis for processing is Art. 6(1)(b) and (c) GDPR.
3. Purposes of data processing
   Personal data is processed in order to handle your request to subscribe to units in the klimaVest ELTIF.
4. Duration of storage
   The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected.

1. Description and scope of data processing
   If you would like to receive a newsletter offered on the website, we will require your e-mail address. Providing your name is voluntary and is only used to address you personally in the newsletter.
   In addition, the following data is collected during registration:
   (1) Date and time of registration
   As part of the registration process, your consent is obtained for the processing of the data, and reference is made to this privacy policy.
   The newsletter is sent by e-mail and contains information about the fund, its performance, industry information and availability. By subscribing to this newsletter, you consent to Commerz Real Fund Management S.à.r.l. processing your data for the purpose of sending the newsletter.
   We use the Eloqua service from Oracle Deutschland B.V. & Co. KG to send the newsletter. Newsletters sent with the help of Eloqua use tracking technologies that make it possible to provide you with content that is appropriate to your interests or to adapt the newsletter to your interests (see point VIII. Web tracking – use of the Eloqua marketing tool). If you no longer wish to receive the newsletter, you can unsubscribe at any time with future effect by clicking on the unsubscribe link in each e-mail.
2. Legal basis for data processing
   If consent has been obtained from the user, the legal basis for the processing of data after subscribing to the newsletter is Art. 6(1)(a) GDPR.
3. Purposes of data processing
   The user’s e-mail address is recorded for the purpose of delivering the newsletter. If a newsletter is subscribed to before the transfer to one of our sales partners, the name of the respective sales partner is also recorded. Collecting this data is necessary to enable us to provide a service, as we continuously optimise our customer process by following up. The collection of other personal data as part of the registration process serves to prevent misuse of the services or the e-mail address used.
4. Duration of storage
   The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s e-mail address and other data collected during registration are therefore stored for as long as the newsletter subscription is active.
5. Objection and deletion options
   The user can cancel their subscription to the newsletter at any time. Each newsletter contains a relevant link for this purpose. Consent to the storage of the personal data collected during the registration process can also be revoked this way. 

Commerz Real Fund Management S.à.r.l. offers you the option of requesting various information materials (white papers and the like) by e-mail via various forms available on the website. For these purposes, your personal data such as your e-mail address and optionally your name are required for us to contact you personally. We use the Eloqua service from Oracle Deutschland B.V. & Co. KG to send advertising materials. E-mails sent with the help of Eloqua use tracking technologies that enable content to be made available to you that suits your interests and/or information offers to be adapted to your interests (see point VIII. Web tracking – use of the Eloqua marketing tool). Commerz Real Fund Management S.à.r.l. processes and uses personal data collected for advertising purposes, provided that we have received your consent pursuant to Art. 6(1)(a) of the General Data Protection Regulation (GDPR). If you no longer wish to receive our offers, you can send your objection with effect for the future at any time by e-mail to werbewiderspruch@commerzreal.com without providing a reason or unsubscribe from our offers at any time via the unsubscribe link in the e-mails

1. Description and scope of data processing
   Our web pages use cookies in several places. Cookies are small text files that are stored on your computer and saved by your browser. They are used, for example, to determine the frequency of use and the number of users of the web pages and thus make the website more user-friendly and effective. “Session cookies”, which are temporarily stored exclusively for the duration of your use of the web pages and then automatically deleted, as well as “persistent cookies” where applicable, are used. The content of a persistent cookie is limited to an identification number in order to record information about users who repeatedly access a web page, recognise you as a user and, if necessary, offer you optimised user guidance. Cookies do not cause any damage to your computer and do not contain viruses. You can prevent cookies from being stored by means of a setting in your browser preferences. If you do not accept cookies, this may restrict the functionality of the web pages.
2. Duration of storage, objection and deletion option
   Cookies are stored on the user’s computer and transmitted to our page by this computer. As a user, you therefore also have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.

Web controlling technologies are used to gather and store data on our websites for optimisation purposes. Cookies can also be used for this purpose, but they only collect and store data in an anonymous form. The data will not be used to personally identify the visitor to this website and will not be merged with data about the anonymized user. You have the option of configuring your browser so that you are notified as soon as cookies are placed in order to reject them if necessary. In addition, you can prevent the installation of cookies by setting your web browser accordingly. However, you may then no longer be able to use all the functions of this website to their full extent. No personal data is stored. A user’s IP address is rendered unidentifiable and does not allow any conclusions to be drawn about the visitors to this website. The legal basis for data processing is Commerz Real Fund Management S.à.r.l.'s legitimate interest pursuant to Art. 6(1)(f) of the General Data Protection Regulation (GDPR). Insofar as personal data is processed, your consent pursuant to Art. 6(1)(a) GDPR constitutes the legal basis.

1. Management of tracking services:
   The following tracking services are currently used:
   Use of Google Analytics -> Deactivate Google Analytics
   Use of Eloqua -> Activate/deactivate Eloqua
   
   More information on the use of tracking technologies can be found below.
   
   
2. Use of Google Analytics
   Our website uses Google Analytics, a web analysis service provided by Google Inc. Google Analytics uses “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is generally transmitted to a Google server in the US and stored there. On our website, we use the code extension “anonymizeIp”, which is used to activate IP anonymisation on this website. However, by using this extension, your IP address will be shortened beforehand by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Google will only use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The shortened IP address transmitted by your browser for the purpose of Google Analytics is not combined with other data from Google. You can prevent the storage of cookies by setting your browser software accordingly. However, we would like to point out that if you do so, it may not be possible for you to use all the functions of this website to their full extent. Click here to prevent Google Analytics from collecting data. An opt-out cookie will be set which prevents the future collection of your data when you visit this website. Further information can be found in Google’s privacy policy.
3. Use of the Eloqua marketing tool
   This website uses the Eloqua marketing tool from Oracle Deutschland B.V. & Co. KG for optimal communication with interested parties and investors. The Eloqua servers of the provider Oracle Deutschland B.V. & Co. KG, Riessstrasse 25, 80992 Munich, are located in the EU. In the context of support and administration services, it cannot be ruled out in individual cases that individual employees of Oracle Corporation outside the EU also have access to user data as part of their contractually agreed service provision. As a precaution, we have ensured compliance with an appropriate level of data protection at Oracle Corporation by means of guarantees by agreeing the EU standard contractual clauses for the transfer of personal data to processors in third countries. Eloqua places a permanent cookie on our website, which above all helps us to analyse your use of the website and thus improve the website's delivery. Eloqua stores and analyses the frequency of website visits, the content that is of interest to you and the links that you follow. Based on this information, the content of newsletters and advertising content are also adapted to your interests. Information on data protection in connection with the use of Eloqua can be found here.
4. Use of the Facebook pixel
   Within our online offering, we use the Facebook pixel offered by the social network Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
   With the help of the Facebook pixel, Facebook has the option of defining you, as a visitor to our online offering while logged into Facebook, as a target group for displaying ads (Facebook ads). Accordingly, the Facebook pixel is used by us to display the Facebook advertisements we have placed for such logged in Facebook users who have also shown an interest in our online product offering or who have certain characteristics defined by us and provided to Facebook (e.g. interests). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can continue to track on an anonymised basis the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users have been forwarded to our website after clicking on a Facebook advertisement (“conversion”).
   If you wish to object to the collection and use of your data by the Facebook pixel, you can do so via the page set up by Facebook and follow the instructions on the settings of usage-based advertising there. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices. You can furthermore object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative and the European website youronlinechoices.com.
   Further information on the Facebook pixel and Facebook’s privacy policy can be found here.
5. Security
   Commerz Real Fund Management S.à.r.l. cannot assume any liability for the security of data transmission over the Internet. E-mail messages are not encrypted. Interception by third parties cannot be ruled out. It is therefore recommended that confidential information be sent by post only.
6. Your rights and complaint options
   You have the following rights with regard to the data concerning you:
   Right of access,
   Right to rectification or deletion,
   Right to restriction of processing,
   Right to withdraw your consent,
   Right to object to processing,
   Right to data portability.
   To exercise your rights, please contact Commerz Real Fund Management S.à.r.l.'s Data Protection Officer: datenschutzbeauftragter@commerzreal.com.
   You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data.

1. Description and scope of data processing
   We have integrated Microsoft Forms components on our website. Microsoft Forms allows us to create surveys and display them to users. Users have the option of voluntarily participating in surveys. We cannot rule out that personal data may also be transferred to and processed by Microsoft Corporation in the USA in individual cases. Further information on the processing of personal data by Microsoft can be found at privacy.microsoft.com/de-de/privacystatement.
2. Legal basis for data processing
   If personal data is collected in surveys beyond the provision of the survey, the legal basis for the processing of the personal data is the consent of the user Art. 6(1)(a) GDPR. We cannot rule out the possibility that, in individual cases, personal data may also be transmitted by Microsoft to Microsoft Corporation in the USA and processed there. Further information on the processing of personal data by Microsoft can be found at privacy.microsoft.com/de-de/privacystatement
3. Purposes of data processing
   The purpose of processing personal data based on consent is solely for the purpose described in the consent, i.e. contacting us.
4. Duration of storage
   The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected.
5. Objection and deletion option
   The user has the option of withdrawing their consent to the processing of personal data at any time. If the user contacts us by e-mail, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. In this case, all personal data stored in the course of making contact will be erased.

1. Scope of data collection and storage
   Data generated by user interactions such as posts, likes, etc. are used for the purpose of processing user communications via social media. Cookies, demographic data (e.g. based on age, place of residence, language or gender information), statistical data on user interactions in aggregated form, i.e. without personal reference (e.g. page activities, page views, page previews, likes, recommendations, posts, videos, page subscriptions incl. origin, times of day) are used for the purpose of target group-specific advertising.
   
   In order to provide the social media service, e.g. in the form of our Facebook or Instagram fan pages and YouTube or LinkedIn, the platform operators generally store cookies on the user’s end device. These include session cookies that are deleted when the browser is closed and persistent cookies that remain on the end device until they expire or are deleted by the user. When a website is visited, a cookie is stored in a text file on the computer. This cookie is then retrieved and read the next time the web server is called up. As a user, you can decide yourself via your browser settings whether and which cookies you want to allow, block or delete. Instructions for your browser can be found here: Internet Explorer, Firefox, Google Chrome, Google Chrome mobile, Microsoft Edge, Safari, Safari mobile. Alternatively, you can also install ad blockers, such as Ghostery.
2. Information on the social media platforms we are present on
   Facebook 
   According to information provided by Facebook, its cookies are used for authentication, security, website and product integrity, advertising and measurements, website functions and services, performance as well as analysis and research. Details on the cookies used by Facebook (e.g. names of cookies, duration of service, content collected and purpose) can be viewed here: www.facebook.com/policies/cookies/ by following the links there. This page also provides details of how to deactivate the cookies used by Facebook. You can also change the settings for your advertising preferences there. Privacy settings can be changed under this link: www.facebook.com/help/193677450678703   
   LinkedIn
   According to Information provided by LinkedIn, its cookies are used for authentication, security, preferences, functions and services, advertising, performance, analytics and research. If you want to find out more about cookies, please see: www.linkedin.com/legal/cookie-policy. Further information on how to manage the cookies used can be found at: https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacy-policy&lang=de
3. Objection options
   You can also object to the collection and storage of data arising from the use of the above-mentioned social media platforms’ cookies at any time with future effect by following the opt-out link (for the providers listed there): http://www.youronlinechoices.com/de/praferenzmanagement/.
   
   You can manage your preferences with regard to usage-based online advertising via this link. If you object to usage-based online advertising from a specific provider with the help of the preference manager, this only applies to the specific business data collection via the web browser currently in use. Preference management is cookie-based. Deleting all browser cookies will also delete the preferences you have set in the preference manager.
4. Note on Facebook Insights
   We use the Facebook Insights function for statistical evaluation purposes. In this context, we receive anonymised data on the users of our Facebook fan page. It does not allow us to identify you personally. For more information, please see Facebook’s Cookie Policy.
5. YouTube
   We would like to provide you with a broad range of multimedia information. For this reason, we include YouTube videos (YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA).
   The videos are integrated in extended data protection mode or by using the no-cookie solution, meaning that cookies and pixel tags are only set by YouTube to personalise advertising and search results once the video has been played.
   
   When the YouTube video is played, the following data is transmitted to Google as the YouTube operator:
   the IP address,
   the specific address of the page accessed by us,
   the transmitted identifier of the browser and
   the system date and time of access, and
   existing cookies that can be used to uniquely identify your browser.
   Google, as the operator of YouTube, is solely responsible for processing this data. More information can be found here.
   Please note that Google may receive further data about cookies already stored by you. The extent to which these are used by Google is beyond our control.
   YouTube’s privacy policy can be found here. 
6. Disclosure and use of personal data
   Platform operators
   If you interact within the framework of the social media platform, the respective platform operator will of course also have access to your data. Your data can therefore be accessed by: Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA, and YouTube operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
   Platform operators may be located in an insecure third country where the level of data protection is lower. 

The controller as defined by the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is: 

Commerz Real Fund Management S.à.r.l.

Rue Albert Borschette 8
Luxembourg
Luxembourg
L-1246

klimavest@commerzreal.com