PRIVACY POLICY FOR NON-REGISTERED OPENFUNDS.COM USERS

1. Introduction

This Privacy Policy describes how openfunds e.V. (“openfunds”) collects, uses and handles personal information. It further describes why we collect personal information, how we use cookies, when and how we share personal information with third parties and how we keep your personal information secure.
“openfunds website” or “openfunds” refers to www.openfunds.org.

2. The EU Representative

As openfunds AG is registered in Switzerland and offers services to investors in the European Union, it has appointed fundinfo (Germany) GmbH as its EU Representative.
The contact details of fundinfo (Germany) GmbH are as follows:
Rheinstraße 13
60325 Frankfurt am Main
Germany Phone: +49 69 750 859 790
Email: info@fundinfo.com

3. The Data Protection Officer

Mr Daniel Walter, Managing Director, has been appointed as Data Protection Officer. Mr Walter can be contacted at daniel.walter@openfunds.org or openfunds e.V., Staffelstrasse 12, 8045 Zurich, Switzerland.

4. What personal information do we collect?

If you do not create an account with openfunds we do not collect any personal information.

If you create an account with openfunds the personal information we collect will include:
• e-mail address;
• password;

If you subscribe to the openfunds newsletter the personal information we collect will include:
• -mail address;

5. Why do we collect personal information and how do we use it?

Only active members are allowed to login on openfunds.org. The personal data is collected to check the member status of the user. We also use your personal information to perform marketing related activities and to supply other administrative services.

If you subscribe to the openfunds newsletter we use the personal data to provide newsletters only.

6. Lawful basis for processing your personal data

openfunds will process your data in a lawful, fair and transparent manner.
Your personal data is processed because you have consented to the processing of your personal data for the purpose of using the services provided by openfunds.

7. How long do we hold your information for?

If you create an account or if you subscribe to the newsletter your personal data related to this registration is collected and held by openfunds for as long as is necessary for you to maintain an account with us. Once the account has been closed, any data retention will only be to the extent necessary for us to comply with our legal obligations, enforce our agreements, internal analysis purposes or to improve website functionality.

8. Cookies

I. In general

A cookie is a small file which a website puts on a computer or other device so that the website can remember something about you at a later time. openfunds requires to use cookies to enhance its website functionalities by tailoring its services for you based.

These cookies will not be used for any purposes other than the ones stated above. The cookies we used are “essential”: this means that our cookies are strictly necessary for us to provide you with the service that you have consented to when accessing our website. As such, we do not provide for a mechanism of “opting-out”. If you do not accept our cookies you will not be able to avail of the services offered by openfunds.com.

II. List of cookies used by openfunds

Cookie Name Default Expiration Time Description
TSxxxxxxxx End of browser session Main ASM Cookie
f5avrbbbbbbbbbbbbbbbb End of browser session Session cookie created for application visibility reporting
ARRAffinity End of browser session Session Persistence
qtrans_front_language 1 year Language Selection

III. List of cookies if you create an account

Cookie Name Default Expiration Time Description
TSxxxxxxxx End of browser session Main ASM Cookie
wordpress_logged_in_[hash] End of browser session Session Persistence
wordpress_sec_[hash] End of browser session Session Persistence

9. Sharing of personal information with third parties

If you do not create an account with openfunds we will generally not make your personal information available to any third party.
Under exceptional circumstances, we may make your data available to third-party service providers who help us 1) administer openfunds.com or 2) process the data submitted to it. These providers will not use the data for their own purposes.

10. Links to other web-sites

openfunds may provide links to one or more other third party websites. We encourage you to read their individual privacy policies before providing any of your personal information to them.
openfunds is not responsible for the privacy policy adopted by third party web-sites.

11. Children’s data

openfunds is intended for use by persons aged 18 and over. openfunds does not knowingly collect or solicit any information from anyone under the age of 18. The services offered by openfunds and its content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

12. Your rights under Privacy Law

Your rights include:

I. The right to be informed of the processing operation and purpose

You have the right to be informed of the source of the personal information, of the purposes and methods of the processing, of the identification information concerning the entity responsible for collecting and processing your personal information, of the entities or categories of entity to whom or which your personal information may be communicated and who or which may get to know said information, etc.

II. The right of access

You have the right to obtain confirmation from openfunds on whether or not your personal data is being processed and if so, to request further information on the processing.

III. The right to rectification

You have the right to rectify any inaccurate personal data, without delay.

IV. The right to erasure (“to be forgotten”)

You have the right to obtain erasure of your personal data without delay, where certain grounds apply.

V. The right of restriction to data processing

You have the right to obtain restriction to the processing of your data by openfunds, where certain grounds apply.

VI. The right to withdraw consent

You have the right to withdraw consent at any time without charge.

VII. The right to lodge a complaint with a supervisory authority

VIII. The right to data portability

You have the right to receive the data you have provided to openfunds in a structured, commonly used, machine-readable format and to send this data onto another data controller.
For the purpose of exercising the rights described above, you may contact the Data Protection Officer email: daniel.walter@openfunds.org or write to openfunds e.V., Staffelstrasse 12, 8045 Zurich, Switzerland.

13. Transfers to third country jurisdictions

openfunds is based in Switzerland. The European Commission has recognised Switzerland as providing an adequate level of protection of personal data. Your personal data may be transferred across international borders. It may be transferred to countries that have different levels of data protection laws to the country from where you submitted your personal data. openfunds has put in place security measures for the export of personal data from its jurisdiction and has made arrangements with entities receiving your personal data such as, that they shall ensure that security measures are in place, and that your personal data is processed only in accordance with EU Data Protection laws.
If data is transferred from within the EEA to a jurisdiction outside the EEA, it is done so under our binding cooperate rules, which contain a high standard of data protection rules and provide safeguards for personal information that is transferred outside of the EEA.

14. Security of your personal information

openfunds takes reasonable measures to ensure the security of your personal information. In particular, we take steps to protect against unauthorised access to disclosure of or alteration of your personal information. The steps we take to protect the security of your personal information include the putting in place of industry standard firewalls and password protection systems.

15. Consent to this Privacy Policy

By clicking “I accept the privacy policy” on the entry pop-up you consent to the collection and use of your data, as described in this Privacy Policy.

15th May 2018