Orthrus Asset Management

Data protection

Your trust is important to us. Orthrus AM Ltd takes the protection of your personal data very seriously. Personal data are only collected, processed or used if the data subject has given their consent, if this is necessary for the performance of a contract or if a law permits or prescribes the collection, processing or use.

With this data protection declaration we would like to inform you about the details of the data collection and data processing as well as about your rights in this context.

1. Name and address of the person responsible

The person responsible within the meaning of the General Data Protection Regulation of other data protection laws applicable in the member states of the European Union and other data protection regulations is:

​

ORTHRUS AM LTD

20-22 Wenlock Road

London, England, N1 7GU

 

info@orthrus.online

 

2. Basic information on the processing of personal data

Personal data is all information that relates to an identified or identifiable natural person (hereinafter "data subject"). A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical , physiological, genetic, psychological, economic, cultural or social identity of this natural person.

Orthrus AM Ltd processes personal data only if the user gives his consent or if the data processing is permitted by legal regulations. The legal basis is Article 6, Paragraph 1 of the EU General Data Protection Regulation (GDPR). According to this regulation, the processing of personal data is only permitted if the person concerned consents (Art. 6 Paragraph 1 lit. a GDPR) or the processing is necessary for one of the following purposes:

To fulfill a contract with the person concerned or to carry out pre-contractual measures at the request of the person concerned (Art. 6 Paragraph 1 lit. b GDPR).

• To fulfill a legal obligation of our company (Art. 6 Paragraph 1 lit. c GDPR).

• To protect the vital interests of the data subject or another natural person (Art. 6 Paragraph 1 lit. d GDPR).

• To perform a task that is in the public interest or that has been assigned to our company by the public administration (Art. 6 Paragraph 1 lit. e GDPR).

• To safeguard the legitimate interests of our company or a third party, unless the interests, fundamental rights and freedoms of the data subject for the protection of personal data prevail (Art. 6 Paragraph 1 lit. f GDPR).

3. Storage duration and data deletion

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage can also take place if this has been provided for by law. The data will also be blocked or deleted if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data in order to conclude or fulfill a contract. Prescribed storage periods in this sense are, for example, retention periods under tax law or commercial law.

4. Recording of access data (creation of log files)

The Orthrus AM Ltd website automatically collects general data and information from the computer system of the calling computer each time it is accessed, which is stored in the server's log files. The following data and information are recorded:

• Browser type including version used

• Operating system used by the calling computer

• Date and time of the call

• IP address of the user

• Internet service provider of the user

• Website from which our website is accessed

• Websites and sub-websites that are accessed from our website

• Other similar data and information used to avert threats in the event of attacks on our system

The data is stored anonymously in the log files of our system. There is no link to other personal data of the user. Orthrus AM Ltd does not draw any conclusions about the person concerned.

The legal basis for data processing is Article 6 (1) lit. f GDPR. The storage is necessary to ensure the functionality of our website and the correct presentation of the content. Furthermore, the data serve our statistics and the constant optimization of our content. Finally, it is stored in order to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack.

The data will not be passed on to third parties unless there is a statutory disclosure requirement.

Since the collection and storage of the data in the log files is absolutely necessary for the trouble-free operation of the website, there is no possibility for the user to object.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Insofar as the survey was carried out for the functional provision of the website, this is the case when the internet session ends.

5. Cookies

We use cookies on our website. Cookies are text files which our server places on your computer and which stores certain data. Cookies usually contain a characteristic string of characters that enables the internet browser to be clearly assigned when the user visits the website again. This enables the calling browser to be recognized and identified.

Cookies help us to make it easier for you to use the website. Through the recognition of the browser and the storage of previously entered data, the offers and contents of our website can be individually optimized in that the data you enter (e.g. access data, search terms) do not have to be re-entered each time you visit the website. The legal basis for this is Article 6 (1) lit. f GDPR.

In addition, we use cookies on our website that enable an analysis of the surfing behavior of the users. However, the data collected in this way is pseudonymized, ie the personal data are replaced by other identifiers (pseudonyms) so that the person concerned can no longer be identified without the use of additional information. Since your consent is obtained when you visit the website, the legal basis for processing personal data using analysis cookies is Article 6 (1) lit. a GDPR.

Since cookies are stored on the user's computer, you as the user also have full control over the use of cookies. You can deactivate or restrict the transfer of cookies by changing the settings in your internet browser. You can delete cookies that have already been saved at any time. However, if cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

6. Registration on our website

You have the option of registering as a user on our website. The data will be entered by you in an input mask, transmitted to us and saved by us. Which personal data are affected by this can be seen from the input mask. In addition, the user's IP address and the date and time of registration are also saved. At the end of the registration process, we will again obtain the user's consent for data processing. The legal basis for the processing of personal data is therefore Article 6 (1) lit. a GDPR. As far as the storage of the IP address is concerned, the legal basis is also Article 6 (1) lit. f GDPR. The data will not be passed on to third parties unless there is a statutory disclosure requirement.

The registration of the data subject, with the voluntary provision of personal data, enables the data controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. The other data are stored in order to prevent or detect misuse of the website and to ensure the security of our system.

As a registered user, you have the option at any time to change or completely delete the personal data provided during registration. To do this, you can use the functions contained in your account or inform us of your request to change or delete the data in writing or by e-mail.

7. Contact form and email contact

The Orthrus AM Ltd website has a contact form that can be used to contact our company electronically. The data entered by the user in the input mask are transmitted to us and stored. In addition, the user's IP address and the date and time of transmission are also saved. The consent of the user is obtained for the processing of the data as part of the sending process. The legal basis for processing is therefore Article 6 (1) lit. a GDPR. As far as the storage of the IP address is concerned, the legal basis is also Article 6 (1) lit. f GDPR.

Alternatively, you can contact us via the one mentioned on our website
E-mail address possible. In this case, in addition to the e-mail address, the personal data listed by the user in the e-mail will be transmitted. The legal basis for this is Article 6 (1) lit. f GDPR.

The processing of the data transmitted via the contact form or by email is only used to establish the desired contact. The other data are stored in order to prevent or detect misuse of the website and to ensure the security of our system. The data will not be passed on to third parties unless there is a statutory disclosure requirement.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. As far as the data transmitted by the user in the contact form or in the e-mail is concerned, this is the case when the relevant communication has ended, unless the communication content is still legally relevant afterwards.

The data subject has the option at any time to revoke their consent to data processing or to object to the use of the data. In this case, the intended contact with the user is no longer possible or communication that has already started cannot be continued.

8. Use of social plug-ins

We have integrated plug-ins from social networks on our website. If the person concerned is registered with the respective social network when accessing our website and is also logged in, this recognizes which specific subpage of our website the person concerned is calling up. This information is collected by the operator of the social network and assigned to the data subject's account there. We have no influence on the type and scope of the data that is collected, stored and processed by the operator of the social network. For more information, please contact the operator of the respective social network. In order to prevent data about you from being processed by the operator of the respective social network, you must log out of the network concerned before calling up our website. You can also use special tools that block data transmission (e.g. Facebook blockers).

9. Use of Google Analytics

We use the Google Analytics analysis service on our website. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

Google Analytics saves cookies on your computer and thus enables an analysis of your use of the website. The information generated by the cookie, including your IP address, is usually transferred to a Google server in the USA and stored there. However, the transmitted data is anonymized beforehand. On our behalf, Google will statistically evaluate the information transmitted in order to compile reports on website activity and to provide us with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. To prevent this, you can deactivate or restrict the transmission of cookies in the settings of your Internet browser. You can delete cookies that have already been saved at any time. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

IP anonymization

We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. The full IP address is only transmitted to a Google server in the USA and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plugin

You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading the browser plug-in available under the following link and install: https://tools.google.com/dlpage/gaoptout?hl=de.

Objection against data collection

You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie will be set which prevents the collection of your data on future visits to this website: Deactivate Google Analytics.

You can find more information on how Google Analytics handles user data in Google's data protection declaration: https://support.google.com/analytics/answer/6004245?hl=de.

Order data processing

We have concluded a contract data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics in Google Analytics

This website uses the “demographic characteristics” function of Google Analytics. This allows reports to be created that contain statements on the age, gender and interests of the site visitors. This data comes from interest-based advertising from Google as well as from visitor data from third-party providers. These data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the section “Objection to data collection”.

10. Third-party content and services on the deployment and use of YouTube

Our website also contains content and services from third party providers, e.g. videos from YouTube or maps from Google Maps. When you access this content / services via our website, your IP address is usually transmitted to the respective third party provider. This enables these third-party providers to process your user IP address. Even if we try to only involve third-party providers who use IP addresses solely to deliver the content, we have no influence on how the third-party provider concerned uses the data received. For more information, please contact the respective third party provider.

11. Your rights as a data subject

If your personal data is processed, you are the data subject within the meaning of the GDPR and you have the following rights towards us as the person responsible:

 

a) Right to confirmation and information

You can request confirmation from us at any time as to whether we are processing personal data relating to you. If this is the case, you have the right to be informed by us about the following circumstances:

• the categories of personal data that are processed;

• the recipients or the categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed;

• the planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;

• the existence of a right to correction or deletion of your personal data, a right to restrict processing by the person responsible or a right to object to this processing;

• the existence of a right of appeal to a supervisory authority;

• all available information about the origin of the data if the personal data are not collected from the data subject;

• the existence of automated decision-making including profiling in accordance with Art. 22 Para. 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

In addition, you have a right to information as to whether personal data is transmitted to a country that is not a member of the EU (so-called third country) or to an international organization. In this context, you can request to be informed about the appropriate guarantees in accordance with. Art. 46 GDPR to be informed in connection with the transfer.

b) Right to rectification

You have the right to request that we correct any incorrect personal data concerning you without delay. You also have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data - also by means of a supplementary declaration.

c) Right to deletion (right to be forgotten)

You can request that we delete your personal data immediately if one of the following reasons applies:

• The personal data relating to you are no longer necessary for the purposes for which they were collected or otherwise processed.

• You revoke your consent on which the processing was based according to. Art. 6 para. 1 lit. a or Art. 9 Para. 2 lit. a GDPR, and there is no other legal basis for the processing.

• According to Art. 21 Para. 1 GDPR objection to the processing and there are no overriding legitimate reasons for the processing or you submit acc. Art. 21 para. 2 GDPR objection to the processing.

• The personal data concerning you have been processed unlawfully.

• The deletion of the personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the member states to which the person responsible is subject.

• The personal data relating to you was collected in relation to the information society services offered in accordance with Art. 8 Para. 1 GDPR.

If the relevant personal data has been made public by Orthrus AM Ltd and we are obliged to delete the personal data in accordance with the above principles, we are also obliged to inform other persons responsible for data processing that you, as the person concerned, have all of the deletion Have requested links to this personal data or copies or replications of this personal data.

In this regard, we take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, in order to meet these obligations, at least insofar as the processing is no longer required, i.e. legal requirements prescribe this or legitimate interests of deletion conflict.

d) Right to restriction of processing

You can request that we restrict the processing of your personal data under the following conditions:

• The correctness of the personal data is contested for a period of time that enables the person responsible to check the correctness of the personal data.

• The processing is unlawful and instead of a deletion you request the restriction of the use of the personal data.

• The personal data is no longer required by us for the purposes of processing, but you need this data to assert, exercise or defend legal claims.

• You have an objection to the processing acc. Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of Orthrus AM Ltd outweigh your reasons.

If the processing of your personal data has been restricted, this data - apart from its storage - may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest processed by the Union or a Member State. In this case, you will also be informed by us before the restriction is lifted.

e) Right to be informed

If you have asserted the right to correction, deletion or restriction of processing, we are obliged to notify all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. In this respect, you can ask us to be informed about these recipients.

f) Right to data portability ("data portability")

You have the right to receive the personal data concerning you that you have made available to us in a structured, common and machine-readable format. Furthermore, you have the right to transfer this data to another person responsible without hindrance from the person responsible to whom the personal data was provided, provided that the processing is based on the consent pursuant to Art. 6 Para. 1 Letter a GDPR or Art. 9 Para. 2 letter a GDPR or on a contract in accordance with Art. 6 para. 1 letter b GDPR and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task that is in the public interest or in the exercise of official authority , which was transferred to the person responsible.

Furthermore, when exercising your right to data portability in accordance with Art. 20 (1) GDPR, you can request that the personal data be transmitted directly from one person in charge to another person in charge, insofar as this is technically feasible and provided that this does not impair the rights and freedoms of other people will.

g) Right to object

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

Orthrus AM Ltd will no longer process the personal data in the event of an objection, unless we can prove compelling reasons worthy of protection for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or Defense of legal claims.

If the personal data concerning you are processed in order to operate direct mail, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object to processing for direct marketing purposes, the personal data relating to you will no longer be processed for these purposes.

In connection with the use of information society services - regardless of Directive 2002/58 / EC - you have the option of exercising your right of objection by means of automated procedures that use technical specifications.

h) Right to withdraw consent under data protection law

If you have given your consent under data protection law, you have the right to revoke this consent at any time with effect for the future.

i) Automated decisions in individual cases including profiling

You have the right not to exclusively use automated processing
- including profiling - to be subject to a decision that has legal effect on it or similarly significantly affects it, provided that the decision

• is not required for the conclusion or performance of a contract between you and Orthrus AM Ltd

or

• is admissible on the basis of Union or Member State legislation to which the person responsible is subject and this legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the person concerned

or

• takes place with the express consent of the data subject.

However, these decisions may not be based on special categories of personal data according to Art. 9 Para. 1 GDPR, unless Art. 9 Para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

If the decision is necessary to conclude or fulfill a contract between the person concerned and the person responsible, or if it is made with the express consent of the person concerned, Orthrus AM Ltd will take appropriate measures to safeguard the rights and freedoms and legitimate interests of the person concerned upholding, including at least the right to obtain the intervention of a person on the part of the person responsible, to express their own point of view and to contest the decision.

j) Right to lodge a complaint with the supervisory authority

Regardless of your existing rights against us, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, your place of work or the place of the alleged infringement, if you are of the opinion that the processing of your personal data is being carried out violates the GDPR.

The supervisory authority to which the complaint was submitted will inform you of the status and the results of the complaint, including the possibility of a judicial remedy according to Art. 78 GDPR.

The competent supervisory authority for data protection issues is the state data protection officer of the federal state in which our company is based. A list of data protection officers and their contact details can be found at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator, this site uses an SSL or. TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http: //” to “https: //” and by the lock symbol in your browser line.

If the SSL or TLS encryption is activated, the data that you transmit to us cannot be read by third parties.

 

WordPress stats

This website uses the WordPress Stats tool to statistically evaluate visitor access. The provider is Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110-4929, USA.

WordPress Stats uses cookies that are stored on your computer and that allow an analysis of the use of the website. The information generated by the cookies about the use of our website is stored on servers in the USA. Your IP address will be anonymized after processing and before storage.

“WordPress Stats” cookies remain on your device until you delete them.

“WordPress Stats” cookies are stored on the basis of Art. 6 Paragraph 1 lit. f GDPR. The website operator has a legitimate interest in the anonymized analysis of user behavior in order to optimize both its website and its advertising.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when you close the browser. Deactivating cookies may restrict the functionality of our website.

You can object to the collection and use of your data for the future by setting an opt-out cookie in your browser by clicking on this link: https://www.quantcast.com/opt-out/.

If you delete the cookies on your computer, you will have to set the opt-out cookie again.

Google Analytics remarketing

Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

This function makes it possible to link the advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that were adapted to you depending on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have given your consent, Google will link your web and app browser history to your Google account for this purpose. In this way, the same personalized advertising messages can be displayed on every device on which you log in with your Google account.

To support this function, Google Analytics collects Google-authenticated user IDs, which are temporarily linked to our Google Analytics data in order to define and create target groups for cross-device advertising.

You can permanently object to cross-device remarketing / targeting by deactivating personalized advertising in your Google account; follow this link: https://www.google.com/settings/ads/onweb/.

The collected data is summarized in your Google account exclusively on the basis of your consent, which you can give to Google or revoke (Art. 6 Para. 1 lit. a GDPR). In the case of data collection processes that are not merged in your Google account (e.g. because you do not have a Google account or have objected to the merging), the collection of data is based on Art. f GDPR. The legitimate interest arises from the fact that the website operator has an interest in the anonymized analysis of the website visitors for advertising purposes.

Further information and the data protection provisions can be found in Google's data protection declaration at: https://www.google.com/policies/technologies/ads/.

Plugins and tools

Google Web Fonts

This page uses so-called web fonts, which are provided by Google, for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to the Google servers. This gives Google knowledge that our website has been accessed via your IP address. Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR.

If your browser does not support web fonts, a standard font will be used by your computer.

Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's data protection declaration: https://www.google.com/policies/privacy/.

Google Maps

This site uses the Google Maps map service via an API. The provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

To use the functions of Google Maps it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of an appealing presentation of our online offers and to make it easy to find the places we have indicated on the website. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR.

You can find more information on handling user data in Google's data protection declaration: https://www.google.de/intl/de/policies/privacy/.

Objection to advertising mail

We hereby object to the use of the contact data published within the framework of the imprint obligation for sending unsolicited advertising and information materials. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam e-mails.