1. Introduction

prosperity brokershome AG (hereinafter “brokershome”) considers it vital to protect your personal data. This means that only essential data will be collected. brokershome manages the collected data with due care and this data is only processed based on the legal provisions of the European General Data Protection Regulation (hereinafter GDPR) as well as the data protection regulations valid in Liechtenstein. You will be informed below about which of your personal data will be collected by brokershome, what purposes it will be used for, who it will be shared with and what rights of control and information you have.

2. Contact Details of the Responsible Party

prosperity brokershome AG, Industriering 40, 9491 Ruggell, Principality of Liechtenstein, is responsible for processing personal data on the website www.brokershome.li (hereinafter “website”) as specified in the GDPR.

The data protection officer can either be contacted by post using the aforementioned address for the attention of “data protection officer” or by email at datenschutz@brokershome.li.

3. Definitions

3.1
Personal data is all data and information that directly or indirectly relate to an identified or identifiable natural person. This data includes, for example, name, address, email address, telephone number, date of birth, age, gender or the tax identification number.

It is generally possible to use the website without providing any personal data. However, the collection of such data may be necessary if you want to use the services of brokershome.

3.2
Processing is any procedure performed with or without the assistance of automated processes relating to personal data such as collecting, recording, organising, arranging, storing, amending or changing, disclosing or any other type of use.

4. Purpose of Data Processing

brokershome only processes the personal data with your consent for the fulfilment of the contractual relationship or based on the legitimate interests of brokershome. Personal data is generally processed based on the order you have placed and the associated contractual relationship to establish, manage and fulfil contractual relationships. Data is also processed to nurture and maintain customer relationships and for the purpose of personal promotion.

5. Data Security

It goes without saying that brokershome only uses appropriate technical and organisational security measures to protect your data from accidental or intentional manipulation, partial or complete loss, destruction or from unauthorised access by third parties. brokershome also continuously improves security measures according to technological developments.

6. Processing your Personal Data for Website Use

6.1 When visiting the website

When visiting the website, the browser used on your end device automatically sends information to the website’s server. This information is temporarily stored in a so-called log file. The following information will be collected and stored until it is automatically deleted:

  • Visitors (IP addresses are automatically made anonymous)
  • Time of access with indication of the time zone
  • User request (HTTP request method, requested file, version of the HTTP protocol)
  • HTTP status code (response of the server) and size of the server response
  • Name and URL of the retrieved file
  • Website from which access is obtained (referrer URL)
  • • Used browser and the operating system of your computer as well as the name of your access provider

This information is processed in order to allow you to use the website (e.g. by adapting our website to the requirements of your device). This data will not be merged with other data sources.

The legal basis for the lawfulness of data processing is Art. 6, Para. 1(1b) GDPR, as brokershome requires the automatically collected data as part of the pre-contractual legal relationship to ensure the website is effectively prepared, as well as Art. 6, Para. 1(1f) GDPR, as the storage serves the justified interest of brokershome of ensuring the stability and security of the website.

Further information on collecting personal data as part of visiting the website can be found under the section “Cookies” (see Section 8).

brokershome will only store the automatically collected personal data until the aforementioned purposes are fulfilled. This is the case unless brokershome still requires this data for fulfilling the contract or there are legal, statutory or contractual storage periods or the data needs to be stored for an additional period to assert, exercise or refute legal claims.

6.2 Making contact

Personal data that you give to brokershome when making contact using the contact form, by email or with Calendly will be stored and processed by brokershome. brokershome uses this data solely to respond to your query or to make contact and the associated technical administration.

The legal basis for the lawfulness of this data processing is Art. 6, Para. 1(1b) GDPR, as this is used to fulfil the contract between us or corresponding pre-contractual measures, as well as Art. 6, Para. 1(1f) GDPR, as the processing of these queries is mutually beneficial.

Your personal data is stored after responding to the query for a period of three years from the end of the calendar year in which it was responded to. brokershome will then delete your data and only keep it if there are legal, statutory or contractual storage periods or the data needs to be stored for an additional period in order to assert, exercise or defend legal claims.

7. Processing of your Personal Data when using our Services on the Website

brokershome offers services (e.g. creating a user account, making contact, displaying dashboards) on the website and requests personal data from you in order to use them. The required information is always marked as a mandatory field. brokershome cannot provide you with the required service or respond to any of your queries without this information. The following information is required from you:

  • Name
  • Username
  • Email address
  • Login and password information

brokershome stores the data you have provided for the period during which you use your user account if you do not delete it beforehand. You can manage and modify all data in the protected customer area at all times.

The legal basis for the lawfulness of data processing is Art. 6, Para. 1(b) GDPR because it is used to ensure the effective provision and management of the user account within the framework of the contract between you and us.

If there are no exceptions within the services specified below, your personal data will be stored until you delete it or your entire user account. Following the deletion of your user account, your personal data will be deleted after the statutory storage period. Statutory storage obligations or the requirement of your personal data for legal action resulting from misconduct when using a service or in the event of payment problems may result in brokershome storing your personal data for longer.

8. Cookies

brokershome uses cookies on the website. These are small files that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit the website. Cookies do not cause any damage to your end device, do not contain viruses, Trojans or other malware. Information is stored in the cookie that arises in connection with the specifically used end device.

On the one hand, the use of cookies makes using brokershome’s website an easier, more enjoyable experience. As such, brokershome uses so-called session cookies that recognise that you have already visited individual pages on the website before. The data will be deleted as soon as the purpose for which it has been collected is fulfilled. This is the case unless brokershome still requires this data for fulfilling the contract or there are legal, statutory or contractual storage periods or the data needs to be stored for an additional period to assert, exercise or refute legal claims.

brokershome also uses temporary cookies to optimise user-friendliness. They are stored on your end device for a defined period of time. If you visit the website again to use brokershome’s services, the cookies enable us to automatically recognise that you have already visited the website before and what you have entered and what settings you have made so that you do not have to repeat them.

On the other hand, brokershome uses cookies to record website statistics and to optimise the offer. These cookies enable brokershome to automatically recognise that you have already visited the website when you visit it again. These cookies are automatically deleted after a defined period of time.

The data processed by cookies is required for the aforementioned purposes for safeguarding the justified interests of brokershome stated above and the interests of third parties according to Art. 6, Para. 1(1f) GDPR.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a prompt always appears before a new cookie is created. Disabling cookies completely may mean that you are not able to use all the features of the website.

9. Analysis tools

brokershome uses the following tools for analysis. The tracking measures used by brokershome are carried out on the basis of Art. 6, Para. 1(1f) GDPR. brokershome wants to use the tracking measures to ensure that the website is designed to meet the visitor’s needs and is continually optimised. brokershome also uses tracking measures to record website statistics and to optimise the offer. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

9.1 Google Analytics

We use Google Analytics, a web analysis service provided by Google Inc. (https://www.google.de/intl/de/about/), 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, for the purpose of tailoring our platform to meet visitor needs and continuously optimising it.

Google Analytics uses cookies (see Section 9). The information generated by the cookie about your use of this website is generally transferred to a Google server in the United States and stored there. brokershome has activated the IP anonymisation function on this website. This means your Google IP address will be shortened within the Member States of the European Union or in other States party to the Agreement on the European Economic Area before being sent to the USA. The full IP address is only transferred to a Google server in the United States and shortened there in exceptional circumstances. Google will use this information to evaluate its use of the website, to compile reports on activities and to provide other services related to platform and Internet use to brokershome. The IP address sent from your browser in Google Analytics will not be merged with other Google data.

brokershome concluded an agreement with Google for processing order data in accordance with Art. 28 GDPR. For the exceptions where personal data is sent to the USA, Google is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

You can prevent the use of Google Analytics at any time either by installing the Google browser plug-in where an opt-out cookie is set or by choosing the corresponding setting in your browser software. brokershome would like to remind you that you will not be able to make full use of all the functions on the website in this case. Further information can be found under https://tools.google.com/dlpage/gaoptout?hl=de and https://www.google.com/analytics/terms/de.htm. More information on handling user data in Google Analytics can be found in the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=de.

You can also prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on: https://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data protection in connection with Google Analytics can be found under Google Analytics Help https://support.google.com/analytics/answer/6004245?hl=de.

9.2 Salesforce

brokershome uses the services of the provider salesforce.com Germany GmbH, Erik-Mann-Str. 31, 80636 Munich in order to be able to process queries quicker and more efficiently. Salesforce is the world’s leading CRM platform.

Salesforce is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, and offers an additional guarantee of complying with the European data privacy law provided that data is processed in the USA.

Salesforce only uses your data for the technical processing of queries and does not forward it to third parties. You must at least provide a correct email address to use Salesforce. It may be necessary to collect further data while processing service queries (name, address, etc.).

Further information on data protection in connection with Salesforce can be found under https://www.salesforce.com/de/company/privacy/

9.3 Pardot

brokershome uses the services of the analysis tool Pardot for sending newsletters. The provider is salesforce.com, inc., The Landmark at One Market, Suite 300, San Francisco, CA 94105, USA.

brokershome can analyse its newsletter campaigns with Pardot. The email contains a file (web beacon or tracking pixel) and as soon as the email is opened, the data are sent to the Pardot server for analysis purposes. The access data and web beacons are linked to your email address and an individual ID for the evaluation. This makes it possible to determine whether a newsletter message has been opened and which links have been clicked on. The results of the analyses can be used to better adapt future newsletters to the interests of the recipients.

For the cases where personal data is transferred to the USA, Pardot is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

If you do not require an analysis from Pardot, you can reject tracking at any time by clicking on the separate link provided in each email or informing us by sending an email to datenschutz@brokershome.li. The information will be stored as long as you subscribe to the newsletter. After cancelling the subscription, we will store the data purely for statistical purposes and anonymously.

Further information on data protection in connection with Pardot can be found under https://www.salesforce.com/de/company/privacy/

9.4 Calendly

brokershome uses the services of the calendar tool Calendly for arranging appointments with our advisors. The provider is Calendly, 1315 Peachtree St NE, Atlanta, GA 30309, USA.

You, the customer, can use Calendly to arrange an appointment at the time of your choosing with one of our advisors. You will provide your name, email address and, if applicable, email addresses of other people who will be at this appointment. You also have the option of sending a text message.

Calendly is subject to the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework, as personal data is being transferred to the USA.

Further information on data protection in connection with Calendly can be found under https://calendly.com/de/pages/privacy

10. Forwarding of Personal Data to Third Parties

Personal data may be forwarded to third parties that act on behalf of brokershome in order to process the personal data for its underlying purpose, for example performing the services offered, evaluating website user behaviour or technical support. These third parties are contractually obligated by brokershome under statutory agreements to only use personal data for the agreed purpose or to not forward your personal data to other parties without your approval unless this is not required by law. If you would like further information on brokershome’s processors, you can feel free to contact us using the address provided in Section 2. If there are other categories of personal data recipients as part of future data collections, brokershome will inform you of this at the time this information is collected for this purpose.

brokershome is part of the group of prosperity company AG. brokershome may also forward your personal data within the group, to which cashyou AG, prosperity solutions AG and Liechtenstein Life AG with head office in Ruggell/Liechtenstein and prosperity services GmbH with head office in Berlin/Germany belong, to third parties for the purposes of managing contracts or developing and operating products and providing services.

Several recipients are located outside the European Union and the European Economic Area (EEA). Further information on cross-border transfers in general and transfers outside the EEA can be found in Section 11.

If brokershome is legally authorised or obligated to do so (for example based on valid law or a court order), we may disclose your personal data.

11. Transfer of Personal Data to Third Countries

It is sometimes necessary to transfer your aforementioned personal data to countries outside the EU and the EEA (so-called third countries).

Please note that the level of data protection in third countries is not the same as in the EU. However, brokershome will take appropriate measures when transferring your personal data to ensure it is adequately secured. Appropriate guarantees are, for example, an adequacy decision of the EU or the adherence of the company to the Privacy Shield. If none of the guarantees apply, brokershome will conclude standard contractual clauses with the relevant company. You can find them under https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF.

brokershome can send you further details on the guarantees by email on request.

12. Storage Periods

brokershome’s aim is to only process your personal data as little as possible. If no exact storage periods are specified in this policy, brokershome will only store the personal data for the time it is required to fulfil the purpose for which it was originally collected and – if applicable – as long as this is required by law.

13. Your Rights

You have the right to request information on your personal data processed by brokershome. brokershome will provide you with information on the processing purposes, the categories of personal data, the categories of recipients who your data has been or will be disclosed to, the planned storage period and the origin of your data on request. According to the conditions set out in the GDPR, you have the right to correct data, delete data, restrict processing, transfer data - as long as an unreasonable expense is not incurred for the data transfer - and the right to object.

You also have the right to revoke the consent given to use your personal data at any time.

If you are of the opinion that the processing of your personal data by brokershome contradicts the valid data protection provisions, you have the option to file a complaint to the data protection office.

The data protection authority responsible for us is as follows:
Liechtenstein Data Protection Office
Städtle 38
PO BOX 684
FL-9490 Vaduz
Phone: +423 236 60 90
Email: info@dss.llv.li

14. Updates to this Privacy Policy

This Privacy Policy is currently valid and is dated October 2019. brokershome reserves the right to adapt this Privacy Policy to new circumstances at any time.