1. Introduction
With the following information, we would like to give you as a "data subject" an overview of the processing of your personal data by us on our Cryptshare server and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use special services of our company via our pages, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent. The processing of personal data, such as your name, address or e-mail address, is always in line with the General Data Protection Regulation (DSGVO) prevailing in Germany. By means of this notice, we would like to inform you about the scope and purpose of the personal data we collect, use and process. As the controller, we have implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by post.
2. Person in charge
The responsible person within the meaning of DS-GVO is:
Borromin Capital Management GmbH,
Myliusstrasse 47,
60323 Frankfurt am Main,
Germany
Phone: +49 69 50685-0
Fax: +49 69 50685-100
E-mail: info@borromin.com
Representatives of the person in charge: Nicholas Money-Kyrle, Marco Bernecker, James Homer.
3. Definitions
The data protection information is based on the terms used by the European Directive and Ordinance Maker when issuing the General Data Protection Regulation (DS-GVO). Our DATA PROTECTION NOTICE should be easy to read and comprehensible for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms, among others, in this privacy notice:
1. Personal data
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Data subject
Data subject is any identified or identifiable natural person whose personal data are processed by the controller (our company).
3. Processing
Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.
5. Profiling
Profiling is any form of automated processing of personal data which consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
6. Pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
7. Processor
A processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
8. Recipient
A recipient is a natural or legal person, public authority, agency or other body to whom personal data is disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
9. Third party
A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.
10. Consent Consent shall mean any freely given indication of the data subject's wishes for the specific case in an informed and unambiguous manner, in the form of a declaration or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.
4. Legal basis of the processing
Art. 6 (1) lit. a DS-GVO serves our company as the legal basis for processing operations in which we obtain consent for a specific processurpose.ing p
If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 (1) lit. b DS-GVO. The same applies to processing operations that are necessary for the implementation of pre- contractual measures, for example in the case of enquiries about our products or services.
If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c DS- GVO.
Ultimately, processing operations could be based on Art. 6 (1) lit. f DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 DS-GVO).
5. Technology
5.1 SSL/TSL encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact enquiries that you send to us as the operator. You can recognise an encrypted connection by the fact that there is a "https://" instead of a "http://" in the address line of the browser and by the lock symbol in your browser line.
We use this technology to protect your transmitted data.
5.2 Data collection when visiting the website
When you use our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (in so-called "server log files"). Our website collects a series of general data and information each time you or an automated system access a page. This general data and information is stored in the server log files.The following data may be collected:
1. the browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system accesses our website (so-called referrer),
4. the sub-websites which are accessed via an accessing system on our website,
5. the date and time of an access to the website,
6. an Internet protocol address (IP address),
7. the Internet service provider of the accessing system.
When using this general data and information, we do not draw any conclusions about your person. This information is rather required in order to
1. correctly deliver the content of our website,
2. optimise the content of our website as well as the advertising for it,
3. ensure the permanent functionality of our IT systems and the technology of our website, as well as
4. to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Therefore, the data and information collected will be used by us for statistical purposes only and for the purpose of increasing the data protection and data security of our enterprise so as to ensure an optimal level of protection for the personal data we process.The data of the server log files are stored separately from any personal data provided by a data subject.
The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the data collection purposes listed above.
6. Cookies
General information about cookies
We use cookies on our website. These are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.
Information is stored in the cookie that arises in connection with the specific end device used. However, this does not mean that we gain direct knowledge of your identity.
The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you. These cookies enable us to automatically recognise that you have already been to our website when you visit it again. These cookies are automatically deleted after a defined period of time.
7. Cryptshare
This page is our "Cryptshare Server", which is used for the encrypted exchange of files. This data is processed exclusively by and on Borromin servers. The data is not passed on to third parties. Cryptshare is a product that is installed on our servers to enable the exchange of data.
7.1 What personal data is processed in Cryptshare?
Sender information:
To inform recipients of a transfer, the sender's name, phone number and email address are recorded at the time of verification. This information is stored on the sender's computer. Furthermore, this information is used in the e-mail notification of all recipients of a transfer.
The sender's e-mail address and IP address are stored in a server-side system log and transfer log per upload at the time of upload.
Recipient data:
E-mail addresses of all recipients as well as their IP addresses, at the time of a download, are stored in the system log and in the transfer log per download.
E-mail addresses of recipients entered by the sender in the user interface are stored in a database on the server side.
7.2 Why is personal data processed?
Cryptshare is a communication solution based on email communication. In order to provide a convenient way to communicate with each other, the following minimum of personal information is stored:
• The name of the sender is stored on the client side so that the user of the system does not have to re-enter this information each time the system is used.
• Contact information of the sender is sent to the recipients to inform them about the origin of the transfer and how to contact the sender.
• E-mail addresses of senders and recipients are stored on the server side as meta information of the transfer (technical requirement).
• IP addresses of senders and recipients are stored on the server side for traceability and troubleshooting. • Recipients' e-mail addresses are stored in a server-side database. to provide senders with a convenient way to reuse addresses that have already been used.
7.3 How long is data kept?
Cryptshare web application
Name and phone number of the sender are stored in browser cookies. These cookies are automatically deleted. By default, Cryptshare cookies are deleted after 30 days.
Apart from the automatic deletion of browser cookies, the user can delete these cookies himself at any time, either via the built-in browser function or through the cookie deletion functionality built into Cryptshare.
E-mail addresses of recipients addressed by the sender are stored in a server-side database. This address book stores a maximum number of addresses per sender. If the maximum is exceeded, the addresses that have not been used for the longest time are automatically removed.
Server-side logging
All e-mail addresses and IP addresses are stored in a server-side system log and as meta information per transfer. The retention period for transfer log data is 90 days.
8. Your right as a data subject
8.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data relating to you is being processed.
8.2 Right to information Art. 15 DS-GVO
You have the right to receive information from us at any time and free of charge about the personal data stored about you, as well as a copy of this data in accordance with the statutory provisions.
8.3 Right of rectification Art. 16 DS-GVO
You have the right to request the rectification of inaccurate personal data concerning you. You also have the right to request that incomplete personal data be completed, taking into account the purposes of the processing.
8.4 Deletion Art. 17 DS-GVO
You have the right to demand that we delete the personal data concerning you without delay, provided that one of the reasons provided for by law applies and insofar as the processing or storage is not necessary.
8.5 Restriction of processing Art. 18 DS-GVO
You have the right to demand that we restrict processing if one of the legal requirements is met.
8.6 Data portability Art. 20 DS-GVO
You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Article 6 (1) (a) of the GDPR or Article 9 (2) (a) of the GDPR or on a contract pursuant to Article 6 (1) (b) of the GDPR and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have the personal data transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not affect the rights and freedoms of other persons.
8.7 Objection Art. 21 DS-GVO
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) of the DS-GVO.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.
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 is for the establishment, exercise or defence of legal claims.
In individual cases, we process personal data in order to carry out direct advertising. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is connected with such direct advertising. If you object to us processing your personal data for direct marketing purposes, we will no longer process the personal data for these purposes.
8.8 Revocation of consent under data protection law
You have the right to revoke consent to the processing of personal data at any time with effect for the future.
8.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.
9. Routine storage, deletion and blocking of personal data
We process and store your personal data only for the period of time required to achieve the purpose of storage or if this has been provided for by the legal provisions to which our company is subject. If the purpose of storage no longer applies or if a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
10. Duration of storage of personal data
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted if it is no longer required for the fulfilment or initiation of the contract.
11. Validity and amendment of this data protection notice
This data protection information is currently valid and is as of August 2021. Due to the further development of our Internet pages and offers or due to changes to legal or official requirements, it may become necessary to change this information. You can access and print out the current data protection information at any time on this website.