When you use the von Poll Immobilien GmbH website, the protection of your privacy is very important to us. We have prepared the following information to advise you of the collection, processing and use of your personal data on our websites, applications and social media profiles.
Your personal data is collected, processed and used in accordance with the strict requirements of European data protection law and in accordance with the principles of data minimisation, transparency and data security. Von Poll Immobilien GmbH and its business and service partners only process and use your data to the extent that is necessary, legally permissible and desired by you in order to implement the contract concluded with you or the approved service and in order to maintain the resulting customer relationship.
§ 1 Information regarding the collection of personal data
(1) The following information describes our collection of personal data when you use our website. “Personal Data” is any data that can be related to you personally, i.e. your name, address, email addresses, user behaviour.
(3) When you contact us by email or a contact form, we store the data you provide (your email address, if applicable your name and your telephone number) in order to answer your questions. We delete the resulting data once storage is no longer necessary, or we limit the processing if statutory retention obligations apply.
(4) If we wish to make use of third-party service providers for individual functions of our offer or wish to use your data for advertising purposes, we will inform you in detail about the respective processes as described below. We will also specify the defined criteria for the storage period.
§ 2 Purpose of data processing
Von Poll Immobilien GmbH (employees and agents), its partners (independent commercial agencies, their agents and employees) and service providers commissioned by us (data processors) process your personal data on the basis of the successful performance and implementation of the contract. Without this legal basis, we are unable to conclude and process the contract with you. Von Poll Immobilien GmbH also uses your personal data to provide you with information about the products and services it offers in the areas of real estate, real estate financing and lifestyle.
(1) Your personal data is processed for the following purposes:
- a) User requests for website registration,
- b) Provision of website services (such as registration, access to account),
- c) Technical measures for statistical evaluation,
- d) Protection against fraud and abuse,
- e) Compliance with legal requirements.
On our website we offer you the services of our independent commercial agencies and our commercial and licensing partners. These include, for example, online offers for extravagant properties, an exclusive marketplace where properties are offered throughout Europe for the purpose of connecting buyers and sellers, and also individual offers for real estate financing. This gives you the opportunity to contact the respective offerors directly without requiring von Poll Immobilien GmbH to store your data. You will find an overview of our current partners here: https://www.von-poll.de/de/unternehmen/standorte. As soon as you use our services, provide us with your personal data and give us your permission to process your data, the processing of such data is subject to the following data protection rules of von Poll Immobilien GmbH and the European General Data Protection Regulation (EU GDPR).
§ 3 Data access
Subject to your consent, your data is processed by von Poll Immobilien GmbH in accordance with Art. 5 ff EU GDPR. Specifically, your data is processed by the following persons:
- a) Employees who are authorised to administer the website and provide the related services (such as customer service, IT department, etc.);
- b) Employees in marketing, finance, administration and accounting and other relevant departments;
- c) Third-party companies (such as IT service providers, hosting providers, etc.) to which services have been outsourced in the context of commissioned processing.
- d) Master franchisees, licensed partners and commercial agents who offer real estate nationally and internationally in the user's search for real estate and to whom the user sends a contact request.
- e) Licensed partners who offer individual real estate financing in the context of VON POLL FINANCE and to whom the user sends a contact request.
- f) Licensed partners who offer commercial properties in the context of VON POLL COMMERCIAL and to whom the user sends a contact request.
- g) Licensed partners who offer real estate within the context of VON POLL REAL ESTATE and to whom the user sends a contact request.
§ 4 Your rights
(1) You have the following rights towards us with regard to your personal data:
- a) Right to information,
- b) Right to rectification or erasure,
- c) Right to restriction of processing,
- d) Right to object to the processing,
- e) Right to data portability.
(2) You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data. A list of the data protection supervisory authority including the data protection commissioners and their contact details can be obtained from the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html. The supervisory authority responsible for us in matters of data protection law is the data protection officer of the federal state in which von Poll Immobilien GmbH has its registered office. This is the Hessian Data Protection Officer, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany (https://datenschutz.hessen.de).
§ 5 Collection of personal data when you visit our website
(1) When you use the website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, as such data is technically necessary for us to be able to display our website and guarantee its stability and security (legal basis is Art. 6 (1), sentence 1 (f) EU GDPR):
- a) IP address
- b) Date and time of the query
- c) Time zone difference to Greenwich Mean Time (GMT)
- d) Content of the request (specific webpage)
- e) Access status/HTTP status code
- f) Data quantity transferred in each case
- g) Website from which the request originates
- h) Browser
- i) Operating system and its interface
- j) Language and version of the browser software.
(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are assigned to the browser you use and stored on your device. They allow certain information to be sent to the location placing the cookie (in this case, we place the cookie). Cookies cannot run programmes or pass on viruses to your computer. They serve to make our offering altogether more user friendly and more effective.
- a) This website uses the following types of cookies, the scope and functionality of which are explained below:
- Transient cookies (b)
- Persistent cookies (c).
- b) Transient cookies are deleted automatically when you close the browser. These include in particular “session cookies”. Session cookies store a “session ID” that is used to allocate various queries of your browser to the joint session. They allow your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close the browser.
- c) Persistent cookies are automatically deleted after a specified duration, which can vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.
- d) You can configure your browser settings however you prefer and, for example, refuse to accept third-party cookies or any cookies. Please note that you may not be able to use all the functions of this website if you do so.
- f) The Flash cookies used are not collected by your browser but by your Flash plug-in. We also use HTML5 storage objects, which are stored on your mobile device. These objects store the required data independently of the browser you use and do not have an automatic expiration date. If you do not wish the Flash cookies to be processed, you must install an appropriate add-on, such as Mozilla “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash Killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend manually deleting your cookies and the browser history on a regular basis.
§ 6 Other functions and offers of our website
(1) In addition to the purely informational use of our website, we offer various services which you can use if you are interested in doing so. As a rule, these require you to provide further personal data, which we use to provide the respective service and to which the aforementioned data processing principles apply.
(2) In some cases, we make use of external service providers to process your data. These providers, whom we have carefully selected and contracted, are bound to our instructions and are controlled on a regular basis.
(3) Insofar as our service providers or partners have their headquarters in a state outside the European Economic Area (EEA), we will inform you about the consequences of such situation in the description of the offer.
§ 7 Newsletter
(1) With your consent, you can subscribe to our newsletter, which enables us to inform you of our current real estate offers which we consider to be interesting for you. The properties and services advertised are named in the declaration of consent.
(2) For the registration process for our newsletter, we use the “double opt-in procedure”. In other words, after you register, we send a confirmation email to the email address you have indicated and request that you confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be blocked and automatically deleted. In addition, we store your IP addresses and times of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data.
(3) The only mandatory information for us to send the newsletter is your email address. You may, at your discretion, provide further, separately marked data; we use such data to be able to address you personally. Once you have confirmed, we store your email address for the purpose of sending the newsletter. The legal basis is Art. 6 (1), sentence 1 (a) EU GDPR.
§ 8 Objection to or revocation of your consent to the processing of your data
(1) If you have given your consent allowing us to process your data, you are entitled to revoke your consent at any time. Such revocation will influence the permissibility of our processing your personal data after you have issued your revocation.
(2) Insofar as our processing of your personal data is based on the balance of interests, you are entitled to object to the processing. This is the case if the processing is not necessary for the fulfilment of a contract with you, which we depict in the following description of the functions. If you exercise such objection, we will ask you to explain the reasons why we should not process your personal data as carried out by us. If you are justified in your objections, we will examine the situation and either suspend or adjust the data processing or point out to you our compelling reasons worthy of protection, on the basis of which we will continue the processing.
(3) Of course, you can object at any time to the processing of your personal data for purposes of advertising and data analysis. You can inform us of your objection to advertising, using the following contact data: [all contact details].
§ 9 Web analytics
- 1. Use of Google Analytics
(2) The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
(3) You can prevent the storage of cookies by making the appropriate settings in your browser software; please note that in this case you may not be able to use all the functions of this website to the full extent. You can, however, prevent Google from collecting the information generated by the cookie and related to your use of the website (including your IP address) and from processing this data, by downloading and installing the browser plug-in provided by this link: https://tools.google.com/dlpage/gaoptout?hl=en.
(4) We use Google Analytics to be able to analyse and regularly improve the use of our website. The statistics we obtain allow us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the United States, Google has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 (1), sentence 1 (f) EU GDPR.
(6) This website also uses Google Analytics for a device-independent analysis of visitor flows, which is carried out by means of a user ID. You can deactivate the cross-device analysis of your usage in your customer account under “My data”/“Personal data”.
§ 10 Social media
- 2. Use of social media plug-ins
(1) We currently use the following social media plug-ins: Facebook, Google+, Twitter, Xing, T3N, LinkedIn, Flattr, YouTube, Instagram, Pinterest. You can recognise the provider of the plug-in by the marking on the box above its initial letter or the logo. By offering you the button, we give you the opportunity to communicate directly with the provider of the plug-in. It is only if you click on the marked field and thereby activate it that the plug-in provider will be informed that you have accessed the corresponding website of our online offer. The data specified in § 3 of this Policy is also transferred. In the case of Facebook and Xing, the IP address is anonymised immediately after data is collected, according to the respective provider in Germany. When you activate the plug-in, you are sending personal data to the respective plug-in provider, where it is then stored (with US-American providers in the United States). Since the plug-in provider collects data mainly via cookies, we recommend that you delete all cookies using your browser's security settings before clicking on the grayed-out box.
(2) We have no influence on the data collected or on the data processing operations, nor are we aware of the full extent of the data collection, the purposes of processing or the retention periods. We also have no information on the deletion of the data collected by the plug-in provider.
(3) The plug-in provider stores the data collected about you in the form of user profiles and uses these for the purposes of advertising, market research and/or the demand-oriented design of its website. Such an evaluation (also for users not logged in) enables us in particular to show needs-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of such user profiles; however, you must contact the respective plug-in provider to exercise this right. The plug-ins enable us to offer you the possibility to interact with social networks and other users, allowing us to improve our offer and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6 (1), sentence 1 (f) EU GDPR.
(4) The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data we have collected is directly assigned to your existing account with the plug-in provider. If you click on the activated button and, for example, link the page, the plug-in provider will also store this information in your user account and share it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button; this way you can avoid having your visit assigned to your profile with the plug-in provider.
(6) Addresses of the respective plug-in providers and URL with their privacy statements:
- a) Facebook Inc., 1601 S California Ave., Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
- b) Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=de. Google has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
- c) Twitter, Inc., 1355 Market St., Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
- d) Xing AG, Gänsemarkt 43, 20354 Hamburg, DE; http://www.xing.com/privacy.
- e) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
- f) Whatsapp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; https://www.whatsapp.com/legal/
- 2. Integration of YouTube videos
(1) We have integrated YouTube videos in our online offering; these are stored at http://www.YouTube.com and can be played directly from our website.
(2) When you visit our website, YouTube receives notification that you have accessed the corresponding subpage of our website. The data specified in § 3 of this Policy is also transferred. This takes place regardless of whether YouTube provides a user account that you are logged in with, or no user account exists. If you are logged in to YouTube, your data is directly allocated to your account. If you do not wish the data to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data in the form of usage profiles and uses it for purposes of advertising, market research and/or the demand-oriented design of its website. Such an evaluation (also for users not logged in) enables us in particular to provide needs-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of such user profiles; you must contact YouTube to exercise this right.
- 3. Integration of Google Maps
(1) On this website we make use of the offer of Google Maps. This allows us to display interactive maps directly on the website and to enable you to conveniently use the map function.
(2) When you visit our website, Google receives notification that you have accessed the corresponding subpage of our website. The data specified in § 3 of this Policy is also transferred. This takes place regardless of whether Google provides a user account that you are logged in with, or no user account exists. If you are logged in to Google, your data is directly allocated to your account. If you do not wish the data to be associated with your profile on Google, you must log out before activating the button. Google stores your data in the form of usage profiles and uses it for purposes of advertising, market research and/or the demand-oriented design of its website. Such an evaluation (also for users not logged in) enables us in particular to provide needs-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of such user profiles; you must contact Google to exercise this right.
(3) For more information on the purpose and scope of data collection and its processing on the part of the plug-in provider, please see the provider's privacy policies. There you will also find further information about your rights in this regard and your options for using settings to protect your privacy: https://policies.google.com/privacy?hl=en. Google also processes your personal data in the USA and has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
- 4. Integration of mobile applications (iOS/Android)
Once our mobile application (app) is purchased and installed on a mobile device (iOS / Android), particulars about the personal or factual circumstances of an identified or identifiable person (personal data) are collected, processed and used. The collection of such personal data is carried out manually or automatically. The data collected is encrypted on the mobile device and transferred, also in encrypted form, to our server infrastructure.
The manual collection involves data that is required for registration in our app, that is directly related to the use of the app and that is entered manually by the user (“basic data”, including email, IP address, user name and password).
In the case of automatic collection, such data is self-stored information, which especially includes contact information that can be read out; personal, pseudonymous or anonymous usage data that is created for the purpose of the needs-oriented design of the app and that analyse and store user behaviour; and also geographical data that is determined with the help of app-based, location-based services using GPS or WLAN hotspots.
For the app to be used, the following authorisations are required to enable us to guarantee the extensive functions of the app, without which the app cannot function or can only function to a very limited extent:
- a) Creation, search and use of user accounts
- b) Access to the user's photos/media/files/location
- c) Synchronisation with the user account
- d) Retrieval of Internet data
- e) Sending/receiving push messages
- f) Querying network connections
The user can revoke their consent electronically at any time. This is possible during the installation of the app: the user can decide not to agree to the respective query window on the mobile device. After installation and during use, the authorisations can be individually adjusted in the data protection settings of the mobile device. The user's right to object in accordance with § 15 (3) of the German Telemedia Act (TMG) will remain unaffected.
By clicking on the "Delete account" button, users can delete all their personal data.
Once the app is deleted from the mobile device, the user data collected up to such point will remain assignable. No other data will be collected or processed.
§ 11 Online advertising
- 2. Use of Google Adwords Conversion
(1) We use the Google Adwords offer to draw attention to our attractive offers using advertising materials (“Google Adwords”) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. By doing so, we are pursuing our interest in providing you with advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of advertising costs.
(2) These advertising materials are delivered by Google via “ad servers”. For this purpose, we use ad server cookies, which enable us to assess certain parameters for measuring success, such as the insertion of ads or clicks by users. If you access our website via a Google ad, Google Adwords stores a cookie on your PC. These cookies usually expire after 30 days and are not intended to identify you personally. For this cookie, the unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values.
(3) These cookies enable Google to recognise your Internet browser. Insofar as a user visits certain pages of the website of an Adwords customer and the cookie stored on their computer has not expired, Google and the customer can recognise that the user has clicked on the ad and been forwarded to this site. A different cookie is assigned to each Adwords customer. Cookies thus cannot be tracked through the websites of Adwords customers. We ourselves do not collect or process any personal data in the context of the aforementioned advertising measures. We only receive statistical evaluations from Google. On the basis of these evaluations, we can recognise which of the used advertising measures are particularly effective. We do not receive any further data from the use of such advertising material; in particular, we cannot identify users on the basis of this information.
(4) Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. As we have no influence on the scope and further use of the data collected by Google due to our use of this tool, we wish to point out the following, in accordance with our level of knowledge: due to the integration of AdWords Conversion, Google is notified that you have accessed the corresponding part of our website or have clicked on one of our ads. If you are registered with a service provided by Google, Google can assign your visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.
(5) You can prevent your participation in this tracking procedure in various ways:
- a) By setting your browser software accordingly. If you suppress third-party cookies, for example, you will not receive any ads from third-party providers;
- b) By disabling cookies for conversion tracking by setting your browser to block cookies from the “www.googleadservices.com” domain, https://www.google.de/settings/ads. These settings are also deleted when you delete your cookies;
- c) By deactivating the interests-related ads of the providers that are part of the self-regulating campaign “About Ads”, using the link http://www.aboutads.info/choice. This setting is also deleted when you delete your cookies;
- d) By setting permanent deactivation in your browsers (Firefox, Internet Explorer or Google Chrome) with the link http://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to use all the functions of this offer to the full extent.
(6) The legal basis for the processing of your data is Art. 6 (1), sentence 1 (f) EU GDPR. For more information on data protection on Google, please see: http://www.google.com/intl/de/policies/privacy and https://services.google.com/siteestats/de.html. Alternatively, you can visit the Network Advertising Initiative website at http://www.networkadvertising.org. Google has agreed to be subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.