Privacy Policy

Most recent update: 12/2022

ThomasLloyd Global Asset Management GmbH (‘ThomasLloyd’, ‘we’, ‘us’, ‘our’) is the operator of these websites¹ (‘website’).

With the following data protection information for the website, we explain to you what personal data we collect, the purposes for which we process it and the rights you are entitled to when you visit the website and use it and its individual functions. The protection of your personal data is very important to us.

According to the EU Data Protection Basic Regulation ("DSGVO"), personal data is any information relating to an identified or identifiable natural person ("data subject"). An identifiable person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more special personal characteristics. Accordingly, personal data include both your personal data, such as your name, your postal address or your e-mail address, and the technical data generated or processed during the use of the website, which can be assigned to you, such as the IP address, the operating system or the browser of your terminal device or your user behavior recorded via so-called cookies.

1. Responsible Person for Data Protection

The person responsible for the collection and processing of
your personal data when visiting and using the website is

ThomasLloyd Global Asset Management GmbH
Hopfenstraße 8
80335 Munich
Germany
Tel: 00800 090 000 66 (This phone number is only accessible from a landline.)
Fax: 00800 090 000 99

E-mail: info@thomas-lloyd.com

Further information on ThomasLloyd Global Asset Management GmbH can be found at https://www.thomas-lloyd.com/en/imprint/.

2. Data Protection

If you have any questions, concerns or suggestions regarding data protection regarding the website, you can contact us at any time:

ThomasLloyd Global Asset Management GmbH
Hopfenstraße 8
80335 Munich 
Germany

E-mail: gdpr@thomas-lloyd.com

You can also exercise your rights as a data subject here. You will find more detailed information on this in section 8.

3. Automatic Data Processing for Visits to our Website (Purposes of the Processing and Legal Basis)

Visiting our website and using it for purely informational purposes is possible without you having to provide (through registration or transmission in online forms) personal data, such as your name, postal address or E-Mail address, or us to collect such personal data.

However, in order to be able to view our website and to use it in a user-friendly, effective, stable and secure manner, we automatically collect and process the necessary (pseudonymous) technical data in conjunction with your end device and your browser.

3.1. Automatic Data Processing and Processing by the Web Server

In order to show you the individual web pages belonging to our website, our web servers automatically collect and process the following personal data transmitted by your browser:

• IP address of the end device you are using to access our website

• Name and URL of the accessed file;

• Date and time of access;

• Transmitted data volume;

• Notification about whether the file retrieval was successful;

• Recognition data (type, version and language) of the browser and operating system of the end device used for your access

• URL of the website that referred you to us, if accessed via link; and additionally search term, if accessed via search engine, and

• Name of your Internet access provider.

The legal basis for this data processing is point (b) Article 6 (1) GDPR. The data processing is necessary for the implementation of pre-contractual measures taken at your request, since such pre-contractual measures also include website visits.

The (pseudonymous) technical communication data collected and processed to enable the use of the website (connection establishment) are temporarily stored by our web servers in log files, so-called server log files. We use the server log files for internal system-related purposes, in particular for technical administration and to ensure the stability and security of our web servers and website, e.g. to identify and track unauthorized or abusive access attempts to our web servers via the stored IP address. We also use the server log files for statistical purposes in order to record and evaluate access to our website and its contents in a pseudonymised form and, on this basis, to be able to design and optimize our website to make it more needs-oriented, user-friendly and effective. The legal basis for this data processing of the server log files is point (f) Article 6 (1) GDPR, which permits the processing of personal data within the scope of our "legitimate interests", unless your basic rights, fundamental freedoms or interests outweigh the data processing. Our legitimate interests consist in the easy and secure administration of our website or in the measurement, analysis and improvement of our website.

3.2. Cookies

When you visit and use our website, so-called cookies are also stored on your end device. Cookies are small text files that are stored on your hard drive in accordance with the browser you are using and through which certain information flows to the site that sets the cookie (in this case, by us). Cookies cannot execute programs, infect your end device or cause any other damage to your end device. Their overall purpose is to make the website more user-friendly, effective, stable and secure.

You can adjust your browser settings so that you are notified if cookies are set or to allow cookies only in individual cases, to prevent cookies from being accepted in specific cases or generally and to activate the automatic erasure of cookies upon closing your browser. If you deactivate cookies, however, the functions and offers of our website may be limited.

Our website uses the following kinds of cookies:

Temporary cookies (also called session cookies or transitory cookies) are automatically deleted when you close the browser. This includes in particular the so-called session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This enables us to recognize your terminal device if you use several web pages of our website or return to our website before you close your browser.

Persistent cookies are automatically deleted after a specified period of time, which can differ from cookie to cookie. You can delete the cookies in the security settings of your browser at any time. Persistent cookies are used to recognize you the next time you visit our website and/or when you return to our website after closing your browser.

Most of the cookies we use are session cookies. They are automatically deleted at the end of your visit or when you close your browser. The persistent cookies we use remain stored on your terminal device until you delete them. These cookies enable us to recognize your browser on your next visit. The following essential cookies (PDF) are used on the website.

The legal basis for the use of the necessary cookies and the data processing carried out with the aid of the necessary cookies is point (f) Article 6(1) of the GDPR, which permits the processing of personal data in the legitimate interest of the person responsible, in so far as your rights, freedoms or interests are not overridden. The legitimate interests of ThomasLloyd consist in the secure and legally compliant operation of the website, without technical error and in an optimal form and its continuous usability as well as in the provision of certain functions and offers of the website requested by you.

In addition, cookies are used on the website by us or by technology partners to measure the usage and analyse your usage behaviour (so-called statistics cookies), about which we will inform you in more detail in the following under 3.3.

You can set your browser so that you are informed about the setting of cookies and individually decide whether to accept them or to accept cookies for certain cases, e.g. Third-party cookies, or generally exclude them, and activate the automatic deletion of cookies when you close the browser. However, if cookies are not accepted or deleted, the functionalities and offers of the website may be limited.

3.3. Use of Google Analytics

The web analysis service from Google Analytics of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google") is used on the website for the purpose of measuring and analysing your usage behaviour and evaluating and improving the website, provided you have given us your relevant prior consent in accordance with point (f) Article 6(1) of the GDPR via the cookie banner displayed before using the website.

Google Analytics uses or Google sets the following statistic cookies, which are stored on your end device and which enable an analysis of the use of the website by you, if you have given your corresponding prior consent via the cookie banner to the setting of these statistic cookies, to the associated data processing and to the transmission of your data collected by the cookies to Google in the USA:

The information generated by the cookies about your use of the website is usually transferred to a Google server in the USA and stored and processed there. However, by activating IP anonymization on this website, your IP address will nevertheless first be truncated by Google within member states of the European Union or in other contractual states of the Agreement on the European Economic Area. Only in exceptional cases will your full IP address be transferred to a Google server in the United States, where it is then truncated. Google will use this information for the purpose of evaluating your use of the website, compiling reports on your website activities and providing other services relating to website activity and internet usage. The processed data can be used to create pseudonymous user profiles of the users. This data processing and in particular also the associated data transmissions to Google in the USA are also carried out on the legal basis of your previous consent given within the framework of the cookie banner in accordance with point (a) Article 6(1) of the GDPR.

You can revoke your consent at any time. Please use one of the following options:

• You notify us that you wish to revoke your consent.

• You can prevent the storage of Google's cookies by setting your browser accordingly. We would like to point out, however, that in this case you may not be able to use all functions of this website to their full extent.

• You can also prevent the collection of data generated by the cookies and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link http://tools.google.com/dlpage/gaoptout?hl=en.

• Alternatively to using the browser plugin or within browsers on mobile devices, please click this link, to set an opt-out cookie that will prevent Google Analytics from collecting data within this website in the future (this opt-out cookie only works in this browser and only for this domain, if you delete your cookies in this browser, you will have to click this link again).

Further information on the terms of use of Google Analytics can be found at the following link https://policies.google.com/terms?hl=en, further information on data protection at https://policies.google.com/technologies/partner-sites?hl=en and in the privacy policy of Google at https://policies.google.com/privacy?hl=en.

The personal or pseudonymous data will be deleted or made anonymous after 26 months.

3.4. Integration of Google Maps

On our website, we also integrate content or service offers from third parties on the legal basis of the legitimate interests of the person responsible within the meaning of point (f) Article 6(1) of the GDPR, in particular for the provision or improvement of certain website functions or for the optimized presentation of the website. This at least presupposes that the third-party providers of these content or service offers receive the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display this content.

Currently, the content and service offer Google Maps of the third-party provider Google is being integrated into the website:

• Interactive maps of the Google service "Google Maps" as part of the website function to search for ThomasLloyd's locations. Google's privacy policy: https://policies.google.com/privacy, Opt-out option https://adssettings.google.com/authenticated

3.5. Embedded YouTube Videos

Our website uses plugins from the video platform YouTube to integrate videos and play them directly on our website. The video platform is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA ("YouTube"). YouTube is a joint venture with Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").

The integration of YouTube videos is carried out in the so-called "extended data protection mode", which according to the provider's information, the storage of user information only starts when the video(s) is/are played. However, the extended data protection mode does not necessarily exclude the transfer of data to YouTube partners. For example, YouTube establishes a connection to the Google DoubleClick network, regardless of whether you are watching a video.

When you activate embedded videos on our website, a connection to the YouTube servers is established and a data transfer is started. We have no influence on the scope and content of the data that is transmitted to YouTube and possibly other YouTube partners by activating the plugin. Among other things, the YouTube server is informed which of our pages you have visited. According to information provided by YouTube, this information is used, among other things, to collect video statistics, improve user-friendliness and prevent abusive behaviour. To do this, YouTube uses cookies to collect information about user behavior. The cookies remain on your terminal device until you delete them. You can prevent YouTube from saving cookies by making the appropriate setting in the browser software (see above).

If you are logged in to your YouTube account, you allow YouTube to assign your browsing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account before activating the play button.

YouTube is used in the interest of an attractive presentation of our online offers. This represents a legitimate interest within the meaning of point (f) Article 6(1) of the GDPR.

For more information on the handling of user data, please refer to the YouTube privacy policy at: https://policies.google.com/privacy.

4. Collection and Processing of Personal Data Provided (Processing Purposes and Legal Basis)

The use of certain functions and offers of our website, such as the contact form or the login to the personal customer account, makes it necessary to collect and process personal data, such as your name or your e-mail address. We only process such personal data on our website if you provide us with this information yourself, particularly in the context of a registration or an online form.

4.1. Contact Form

If you send us enquiries via the contact form on our website, we require at least your name and e-mail address (compulsory information marked with *) in order to process and reply to them. The legal basis for this data processing is under point (f) Article 6(1) of the GDPR. The data processing is necessary for the implementation of a pre-contractual procedure which is carried out in response to your enquiry, as such procedures also include contact requests.

By voluntarily providing further contact details, you make it easier for us to answer your enquiry and contact you. The legal basis for this is under point (f) Article 6(1) of the GDPR, which permits the processing of personal data within the scope of the "legitimate interest" of the person responsible, unless your basic rights, fundamental freedoms or interests outweigh the data processing. Our legitimate interests consist in facilitating the processing of contact requests.

4.2. Login to your Personal Account

On the website you can also log in to your personal customer account with your login data. There you can manage your master data and password. You can also view, among other thing, your inbox, your contracts and documents awaiting your signature. The legal basis for the processing of the login data is point (b) Article 6(1) of the GDPR. The data processing is necessary to set up your personal account.

4.3. Login to Broker Account

On the website you can also log in to your personal broker account as a broker with your login data. There you have the opportunity to manage your master data. You can also view your inbox, contracts and subscription documents, among other things. The legal basis for the processing of the login data is point (b) Article 6(1) of the GDPR. The data processing is required to set up your broker account.

4.4. E-mail Newsletter

You can further register for our e-mail newsletter on our website using the form provided. With your consent, ThomasLloyd Global Asset Management (Switzerland) Ltd. processes the personal data provided in the form in order to inform you by e-mail newsletter about products and events of the ThomasLloyd Group.

The provision of your e-mail address is mandatory for sending the newsletter. The legal basis for the processing of this data is point (a) Article 6(1) of the GDPR. We process this data with your consent. You can revoke your consent at any time and unsubscribe from the e-mail newsletter. This can be done via the link contained in each newsletter, by writing to the contact details given in the imprint or by sending an E-mail to gdpr@thomas-lloyd.com.

In addition, you can voluntarily provide us with further personal data to enable us to address you personally on other contact channels. The processing of the data that you voluntarily provide us with is based on point (f) Article 6(1) of the GDPR. According to this article, processing is permitted if it is necessary to protect our legitimate interests. Our legitimate interest is to improve the quality of our advice and to be able to contact you more easily in the event of any queries.

For the registration to our newsletter, we use the so-called double-opt-in procedure. This means that after your registration we will send you an e-mail to the e-mail address provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within [24 hours], your information will be automatically deleted. In addition, we store your IP address and the time of registration and confirmation. The purpose of this procedure is to provide evidence of your registration and, if necessary, to clarify any possible misuse of your personal data. In addition, we save your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if applicable, to clarify any possible misuse of your personal data.

5. Recipients of Personal Data

The personal data collected by us in the course of the visit and the purely informative use of our website (see section 3.1.) and also the personal data collected by us in the course of the use of certain functions and offers of our website, such as the contact form or the login to the personal customer account, will only be passed on to third parties to the extent and for the purposes explained in section 3 in each case with the corresponding legal basis.

Personal data provided by you in the context of online forms will also only be passed on to third parties to the extent and for the purposes explained in section 4 or in the data protection notices at the appropriate place on the website, in each case with the corresponding legal basis. This applies in particular to cases in which certain personal data are passed on within the ThomasLloyd Group within the scope of the processing purposes notified to you in advance on a legal basis or with your prior consent in a permissible manner and to the extent necessary.

Otherwise, neither the personal data automatically collected during your visit and the purely informative use of the website in accordance with section 3 nor the personal data provided by you in the context of online forms in accordance with section 4 will, as a matter of principle, be passed on or otherwise transmitted to third parties. An exception applies to compulsory transfers of personal data to government institutions and authorities, to private rights holders on the basis of legal requirements or decisions of a court or authority, or the necessary disclosure to government institutions and authorities for the purposes of legal action or criminal prosecution in the case of attacks against our legal interests.

In operating our website and delivering and carrying out individual website features and offerings, we nevertheless make partial use of external technical and other service providers, as well as companies within the group, to support us in delivering our services. Where necessary, these service providers we use will process your personal data within the scope of their respective orders in accordance with our instructions for the purposes stated in this data protection notice. They are contractually obliged to comply strictly with this data protection notice, the applicable statutory data protection provisions and our instructions (so-called processors pursuant to Article 28 of the GDPR). The same applies to any subcontractors, insofar as our processors use them with our prior consent.

We engage data processors, in particular, to host our website and to process contact form requests.

6. Processing of Personal Data in ‘Third Countries’

The personal data collected by us are processed exclusively within the EU and Switzerland. A transfer of personal data into other ‘third countries’, meaning to countries outside of the EU and the EEA, does not take place. For Switzerland, an adequacy decision of the European Commission in accordance with Article 45 of the GDPR exists, which establishes that an adequate level of data protection exists in Switzerland.

7. Period of Storage 

In general, we only store personal data for as long as this is necessary to fulfil the purpose of the respective data processing or if you request us to delete the personal data for other justified reasons ((see Article 17[1] of the GDPR)). After expiry of these storage periods or upon your justified request for deletion, we will check in each case whether certain personal data are still required for (other) legitimate purposes and, if not, whether contractual or statutory storage periods conflict with deletion of the personal data. In these cases, the personal data concerned will be retained for as long as necessary to fulfil this (other) legitimate purpose or for the duration of the respective contractual or statutory retention period for these purposes. For other purposes, however, they are blocked and then permanently deleted after expiry of the respective last contractual or statutory retention period.

We store the technical communication data contained in the server log files (see section 3.1.) for no longer than six months for the purposes of easy and secure administration of our website and for the purposes of measuring, analysing and improving our website.

The session cookies we use are deleted when you close your browser. We delete the persistent cookies we use after a maximum of six months (see section 3.2. on cookies). The personal data collected via Google Analytics are deleted immediately with anonymisation of the IP addresses (see section 3.3.).

The personal data collected via the contact form (see section 4.1.) is stored by us for six months for processing and answering the enquiry and in the event of follow-up questions. the data associated with your account / broker account (see sections 4.2. and 4.3.) is stored for as long as your user account exists. You can delete your user account at any time by sending us an e-mail to gdpr@thomas-lloyd.com or a message to the address given in the imprint.

The data collected for sending the newsletter (see section 4.4.) is stored for as long as it is necessary to send the newsletter. If you cancel the newsletter, your data will be deleted.

8. Your Rights (Rights of Data Subject)

To the extent that legal conditions in accordance with Article 15 et seq. of the GDPR are given, you have the following rights regarding the personal data stored by us (so-called rights of data subject):

You have the right to obtain from us at any time confirmation as to whether personal data and which categories of personal data about you are stored by us, the purposes they are processed and which recipients or categories of recipients may receive them. Furthermore, you have the right to obtain from us the additional information about your personal data referred to in Article 15 of the GDPR (right of access).

In accordance with legal provisions, you moreover have a right to rectification (Article 16 of the GDPR), a right to erasure (Article 17 of the GDPR) and a right to restriction of processing (for data to be made unavailable) (Article 18 of the GDPR) of your personal data.

In accordance with Article 20 of the GDPR you further have the right to obtain the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format; you have the right to transmit those data or have them transmitted to another controller (right to data portability).

You also have the right to revoke the consent you have given at any time.

In addition, have the right to object to data processing in the case of processing that lies in the legitimate interests of the controller or a third party in accordance with point (f) Article 6(1) of the GDPR where the legal conditions in accordance with Article 21 of the GDPR are given.

To assert your rights as a data subject, you can contact us at any time at gdpr@thomas-lloyd.com.

Additionally, you have the right to lodge a complaint with a supervisory authority for data protection if you are of the opinion that the processing of your personal data breaches data protection law.

9. Data Security

We use comprehensive technical and organisational measures to protect your personal data stored and processed by us against misuse, accidental or deliberate manipulation, loss, access by unauthorised persons and against other data security risks. Our data security measures are continuously improved in line with technological developments. The transmission of personal data occurs by means of encryption according to the latest technology.

Our employees are obliged by us to maintain confidentiality and to comply with the relevant data protection regulations.

10. Chnages to the Data Protection Notice

We can adapt this data protection notice to changed actual or legal circumstances at any time and we will publish the latest version of this data protection notice at this site. The date ("Last updated") at the beginning of this data protection notice indicates when this data protection notice was last changed.