DATA PROTECTION DECLARATION


This website is operated by VMS-REB 3 Beteiligungen GmbH (“we”). Below, we describe how your personal information is processed in connection with this website.

GENERAL PRIVACY POLICY

All data on our website is transmitted via TLS 1.2, AES 128-bit encryption via SSL.

You can basically use our website without revealing your identity. When you visit our website, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information will be collected without your intervention and stored until automated deletion:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Website from which the access takes place (referrer URL)
  • The browser used and, if applicable, the operating system of your computer as well as the name of your access provider

The data mentioned are processed by us for the following:

  • Ensuring a smooth connection to the website
  • Ensuring comfortable use of our website
  • Improvement and development of the website
  • Evaluation of system security and stability
  • Creation of usage statistics
  • Other, further administrative purposes

PURPOSE OF DATA PROCESSING

The legal basis for data processing is Article 6 para 1 lit f of the DSGVO (General Data Protection Regulations). Our legitimate interest lies in the data collection purposes listed above. Under no circumstances do we use the collected data for the purpose of drawing conclusions about you. In addition, we use cookies and analytical services when visiting this website. Further details can be found in the following section. Unless otherwise stated, the data will be stored exclusively on our server (server location: Austria). No data are available to third parties.

We process and store personal data of the data subject only for the period necessary for the achievement of the purpose of the storage or if this was provided by the European directives and regulations or by any other legislator in laws or regulations which the controller is subject to.

If the storage purpose is omitted, or if a storage period prescribed by the European directives and regulatory bodies or any other relevant legislature expires, the personal data will be routinely blocked or deleted pursuant to the statutory provisions.

We can adapt the privacy policy on our website at any time by publishing it.

COOKIES

This website uses so-called “cookies”. These are small files that can be stored on your computer as you visit a website. Basically, cookies are used to provide users with additional functions on a website. They can be used, for example, to help you navigate a website, allow you to re-enter a website at the point where you exited, and/or to remember your preferences and settings when you revisit a website. Cookies cannot access, read or modify any other data on your computer.

Most cookies on this website are so-called “session cookies”, which are automatically deleted when you leave the website. However, we may also use persistent cookies that remain stored on your computer. In this way, we can recognize you on your next visit to our website. If you would like to check whether cookies are stored on your computer, you can activate the corresponding notification function in your browser. Cookies stored on your computer can be blocked or deleted. However, this may prevent you from fully using this website..

LINKS TO OTHER PAGES

We are free to add links (links) to other websites from our website. These websites may be operated by third parties who have other independent privacy policies. Therefore, we have no responsibility for or are responsible for the content, activity, or privacy practices of these sites. We recommend that you read the privacy policy of all the pages you visit, and remind you that this privacy policy applies only to information collected on our website (valuemanagement.at).

USE OF OUR WEB FORMS

For inquiries we offer web forms to contact us. The specification of personal data is obligatory, so that we know from whom the request originated and in order to process it accordingly.

Further information can be provided voluntarily. It is up to you to decide whether you want to enter this information as part of the web form. The data processing for the purpose of contacting us takes place in accordance with Article 6 para 1 S1 lit of the DSGVO (General Data Protection Regulations) on the basis of your voluntarily granted consent by means of a checkbox prior to sending the web form. The personal data we for the use of the web form will be automatically deleted after completion of your request.

TRANSFER OF YOUR PERSONAL DATA

Your personal data will be sent to the following recipients:

  • IT service provider (hosting and maintenance of websites)

YOUR RIGHTS RELATED TO PERSONAL DATA

You have the rights to information, correction, deletion, restriction, data portability, revocation and objection. If you believe that the processing of your data violates data protection laws or if your data protection claims have otherwise been violated in any manner you can file a complaint with the supervisory authority. In Austria, this is the Datenschutzbehörde (Data Protection Authority).

CONTACT INFO

For questions or concerns regarding the processing of your personal data, please contact info@valuemanagement.at

INFORMATION ON DATA PROCESSING UNDER ARTICLE 13 AND 14 GENERAL DATA PROTECTION REGULATIONS (DSGVO)

We hereby inform you about the processing of your personal data and your data protection claims and rights. The content and scope of the data processing depends largely on the services you have requested or agreed upon. For the sake of readability, this document refrains from gender-specific differentiation. Corresponding terms apply in the sense of equal treatment for both sexes.

Responsible for Data Processing

VMS-REB 3 Beteiligungen GmbH, Garnisongasse 4/10, 1090 Vienna, Austria

The Processed Data and their Sources of Origin

We process the personal data that we receive from you in the course of the business relationship. In addition, we process data that we have legitimately received from credit bureaus, debtor directories (such as Compass Verlag, KSV 1870), and from publicly available sources (e.g., business register, club register, land register, media).

In particular, personal information includes your personal details (name, address, contact details, date and place of birth, nationality, etc.), credentials (e.g., ID data), and authentication data (e.g., signature sample). In addition, this may include order data (e.g., payment orders), data from the fulfillment of our contractual obligation (e.g., sales data), information about your financial status (e.g., creditworthiness data), advertising and sales data, documentation data (e.g., call logs), register data, image and sound data (e.g., video or telephone recordings), processing results that we generate ourselves, as well as data to meet legal and regulatory requirements.

Purpose and Legal Basis

We process your personal data in accordance with the data protection regulations. 

For the fulfillment of contractual obligations (Article 6 para 1 lit b of the DSGVO)
The processing of personal data (Article 4 para 2 of the DSGVO) is performed for the provision of financial services, in particular for the execution of our contracts with you and the execution of your orders as well as all activities necessary for the operation and administration of a financial services institution. The purposes of data processing depend primarily on the specific content of the contract and can u.a. Needs analysis, consulting, asset management and support, and transaction execution.

For the fulfillment of legal obligations (Article 6 para 1 lit c of the DSGVO)
The processing of personal data may be required for the purpose of fulfilling various legal obligations (such as the Financial Market Money Laundering Act [FM-GWG], etc.) as well as regulatory requirements (such as the Austrian Financial Market Authority, etc.) to which VMS-REB 3 Beteiligungen GmbH is subject. An example of such a case: reports to the Money Laundering Registration Office in certain suspicious cases (Article 16 FM-MLA).

As part of your consent (Article 6 para 1 lit a of the DSGVO)
When you consent to the processing of your personal data, processing will only take place in accordance with the purposes set out in the consent agreement and to the extent agreed therein. Any consent given may be revoked at any time with future effect (for example, you may object to the processing of your personal information for marketing and promotional purposes if you no longer consent to processing in the future). Please request the revocation directly either via written email or letter to our attention. The revocation of consent does not affect the legality of the data processed on the basis of the consent until the revocation.

For the protection of legitimate interests (Article 6 para 1 lit f of the DSGVO)
As far as necessary, in the interests of VMS-REB 3 Beteiligungen GmbH or a third party, data processing beyond the actual performance of the contract may take place in order to safeguard our legitimate interests or that of third parties. In the following cases, data processing takes place to safeguard legitimate interests:

  • Measures to protect employees and customers
  • Measures for business control, further development of services and products as well as for customer recovery
  • Fraud prevention and control measures
  • In the context of legal action 

Who Receives the Data?

Within the VMS-REB 3 Beteiligungen GmbH, those jobs or employees receive your data required to fulfill their contractual, legal and regulatory obligations. In the event of a legal or regulatory obligation, public authorities and institutions (such as the Austrian Financial Market Supervisory Authority, tax authorities, etc.) may be the recipients of your personal data.

With regard to the transfer of data to other third parties, it should be noted that VMS-REB 3 Beteiligungen GmbH is obliged to maintain secrecy about all customer-related information and facts that have been entrusted or made available to us on the basis of the business relationship. Therefore, we may only disclose your personal data if you have provided prior consent or if we are legally obliged or authorized to do so. Recipients of personal data in this context may be other credit and financial institutions or similar entities to whom we provide data to conduct the business relationship with you (such as correspondent banks, exchanges, custodian banks, credit bureaus, etc.).

Data Storage

We process your personal data, insofar as necessary, for the duration of the entire business relationship (from the initiation, execution to the termination of a contract) as well as in accordance with the statutory storage and documentation requirements pursuant to the Corporate Code (UGB), the Federal Tax Code (BAO), and the Financial Market Money Laundering Act (FM-GwG). Moreover, storage time according to the statute of limitations, for instance, pursuant to the General Civil Code (ABGB) can be considered in certain cases up to 30 years (the general limitation period is three years).

Privacy Rights

You have the right to information, correction, deletion or restriction of the processing of your stored data, a right of objection to the processing, as well as a right to data transferability in accordance with the requirements of data protection law. If you believe that we violate data protection laws when processing your data, we ask you to contact us to clarify your concerns. Complaints can also be directed to the Austrian Data Protection Authority, Wickenburggasse 8, 1080 Vienna, Austria (www.dsb.gv.at).

Obligation to Provide Data

In the context of the business relationship, you must provide the personal data that is necessary for the commencement and implementation of the business relationship and for the collection of which we are legally obliged (see the legal requirements according to FM-GwG, WAG 2018, etc.). If you do not provide us with this data, we will generally be required to disallow the conclusion or execution of the contract, or be unable to complete an existing contract and subsequently terminate it. However, you are not obliged to give your consent to the processing of data that is not relevant to the fulfillment of the contract, nor required by law and/or regulations.

Information on Data Processing in Accordance with the Financial Market Money Laundering Act (FM-GwG)

VMS-REB 3 Beteiligungen GmbH is obliged under the Financial Market Money Laundering Act (FM-GwG), within the framework of its duty towards safeguarding against money laundering and terrorist financing, to obtain and retain certain documents and information from persons upon establishment of the business relationship or on the occasion of an occasional transaction.

VMS-REB 3 Beteiligungen GmbH has, in accordance with FM-GwG and others, to determine and verify the identity of account/custody account holders, beneficial owners of clients or creditors of the account/custody account holder, assess the purpose pursued by the account/custody account holder and the type of business relationship it seeks to obtain, to obtain and review funds, and to continuously monitor the business relationship and the transactions carried out within it. In particular, VMS-REB 3 Beteiligungen GmbH shall keep copies of the received documents and information necessary for the fulfillment of the due diligence obligations described and the transaction documents and records necessary for the determination of transactions.

The FM-GwG grants VMS-REB 3 Beteiligungen GmbH the legal authorization with respect to the data protection laws for the use of the mentioned data of the account/depot owner in the exercise of due diligence to prevent money laundering and terrorist financing, to which VMS-REB 3 Beteiligungen GmbH legally required and serve the public interest. The data processing within the framework of the due diligence obligations described is based on a legal obligation of VMS-REB 3 Beteiligungen GmbH. Hence, an objection by the customer against these data processing cannot be considered by VMS-REB 3 Beteiligungen GmbH.

VMS-REB 3 Beteiligungen GmbH shall delete all personal data that it has processed or stored exclusively on the basis of the FM-GwG for the purposes of preventing money laundering and terrorist financing after a retention period of five years, unless other federal laws require or authorize a longer retention period or the Financial Market Authority sets longer retention periods by decree.

Personal data processed by the Bank solely on the basis of the FM-GwG for the purposes of preventing money laundering and terrorist financing must not be further processed in a manner inconsistent with those purposes. This personal information may not be used for other – such as commercial – purposes.