Data Policy

1. General information, purpose and the responsible authority

This Data Policy informs users about the nature, scope and purposes of the collection, processing and usage (hereinafter collectively referred to as ‘processing’) of their personal data within the website eichenglobal.com and the services and functions connected herewith. The Data Policy applies irrespective of domains, systems, platforms and devices used (e.g, desktop or mobile devices) where eichenglobal.com runs.

The provider of eichenglobal.com and the authority responsible in terms of data protection is EichenGlobal GmbH, Charlottenstr. 18, 10117 Berlin, Germany, https://www.eichenglobal.com/en/imprint/ (under this Data Policy referred to as ‘EichenGlobal GmbH’, ‘we’ or ‘us’).

The term ‘user’ covers clients as well as non-clients of EichenGlobal  GmbH who use eichenglobal.com. The notions used within the framework of this Data Policy such as ‘user’ are gender neutral.

Provided the Data Policy contains permissions, they are to be highlighted.

2. Fundamental information on data processing

We process personal data of users only in compliance with relevant provisions on data protection. It means that personal data of the users are processed only if there is a legal permission or consent.

We take organisational, contractual and technical security measures according to the state of the art, in order to ensure that the provisions of laws on data protection are observed and to protect the data processed by us against accidental or intentional manipulations, loss, or destruction or against access by unauthorised persons.

If within the scope of this Data Policy contents, tools or other means are inserted from other providers (hereinafter collectively referred to as ‘third-party providers’), which are based abroad, it should be assumed that a data transfer occurs in the country where the third-party providers are resident. The transfer of data in third countries occurs either under a legal permission, consent of the user or special contractual clauses that guarantees the security provided by law.

3. Collection, processing and usage of personal data

The personal data of users are processed for the following purposes:

 – Performance of our services

 – Guarantee of an effective customer service and technical support

 – Technical and business-related notifications concerning eichenglobal.com and Eichenglobal GmbH.

We transfer data to third parties based on legal consent or if it is required in order to perform our contractual obligations towards the users. When contacting or demanding a report, the details are stored for request processing as well as for the case of follow-up-question.

If a user makes a comment on the blog, his or her IP address is saved.  It occurs for the purpose of our security, if somebody writes unlawful content in comments (insults, forbidden political propaganda, etc.).
In this case, we also can be held responsible for the comment and therefore are interested in the identity of the comment author.

Personal data are deleted if they have fulfilled the use purpose and if the deletion does not oppose retention obligations.

4. Notifications and newsletter

We send newsletters, emails and other electronic notifications with advertising information (hereinafter referred to as ‘newsletter’) only under the consent of the receiver or under a legal permission. The newsletters contain information about property-related offers and services as well as eichenglobal.com.

However, the notifications sent within the framework of contractual or business relations are not considered advertising. This includes, e.g., sending of service mails with technical or organisational information within the framework of our service provision, instructions concerning technical or legal changes or queries about the orders. The notifications about activities the client is subscribed to, e.g., if they should subscribe to certain search results, shall not be considered advertising as well.

The newsletter is issued approx. once or twice per month. However, they also can be sent unscheduled under special circumstances, advertising campaign etc. So-called double-opt-in-emails, which are sent within the framework of the registration or sign-up for a newsletter, are not advertising messages too. These double-opt-in-emails invite the users to confirm a registration or sign-up. The double-opt-in-emails are necessary to check whether the sign-up was really made by the email owner.

The information about the name and surname is for the personalisation of the newsletter. The users can withdraw their consent for saving the data, email addresses as well as their use for sending the newsletters at any time. The withdrawal can be made, e.g., through an unsubscribe link in the newsletter or with an email to info@eichenglobal.com with “Unsubscribe” in the subject field. The sign-ups for the newsletter are recorded, in order to be able to verify the sign-up process in compliance with legal requirements. For this purpose, in particular, the sign-up and confirmation moment is recorded.

The sending of newsletters occurs through ‘MailChimp’, a newsletter sending platform of the provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. MailChimp is reliable in terms of data protection and we have confidence in its performance and security. You can look through data protection conditions here: http://mailchimp.com/legal/privacy/. However we must point out that the data of newsletter recipients are transferred to the USA. The EU considers the USA unsafe third country in terms of data protection. This is bound up with the fact that there is no uniform data protection law in the USA and that there is political imbalance between the USA and the EU with regard to data protection. However, MailChimp declares in a special contract, which we have accepted, to respect the data protection regulations of the EU. For this reason, MailChimp still has our confidence in a secure data processing. While signing-up for our newsletter its recipient agree with the involvement of MailChimp.

A statistical analysis of reading behaviour only takes place to the extent that we determine whether the recipients opened the newsletter and clicked the links. This is a function of MailChimp, which we only use to check how our newsletter is taken by the users and to optimise it accordingly. For this purpose, the newsletter contains so-called “web-beacon”, a pixel-sized file, which is retrieved from MailChimp’s server when the newsletter is opened.

5. Collection of access data

We collect data about each access to the server where this offer is stored (so-called ‘server log files’). The access data are the name of the website opened, file, date and time of opening, volume of data transferred, report about successful opening, browser type along with its version, user’s operating system, referrer URL (previously visited page), IP address and the requesting provider.

We use log information without allocation to the person of the users or other profiling according to legal regulations only for statistical analysis for the purpose of the operation, security and optimisation of the offer. However, we reserve the right, to check the log information later if based on concrete indications there is a justified suspicion of an unlawful use.

6. Cookies & scope measurement

Cookies are information, which are transferred from our web server or the web servers of third parties to the web browser of the user and are stored for the subsequent openings there. The user are informed according to this Data Policy about the use of cookies within the framework of pseudonym scope measurement.

The viewing of online offers is also possible under exclusion of cookies. If the users do not want the cookies to be stored on their computer, they are asked to deactivate the relevant option in the system settings of their browser. The saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to the functional limitations of the online offers.

It is possible to administer many online offers that are stored in cookies of companies through the US based website http://www.aboutads.info/choices/ or the EU based website http://www.youronlinechoices.com/uk/your-ad-choices/.

7. Involvement of services and contents of third parties

It can happen that within our online offer contents or services of third-party providers, for example, YouTube videos, city maps or graphics from other websites are embedded. The embedding of contents of third-party providers always assumes that the third-party providers recognise the IP addresses of the users because without IP address they cannot sent contents to the browser of the users. The IP address is required therefore for the display of these contents. In addition, the providers of third-party contents can insert own cookies and process the data of the users for own purposes. Based on processed data the usage profiles of the users can be created. We will insert these contents as data-minimising and data-avoiding as possible as well as choose reliable third-party providers with regard to data security.

The following presentation provides an overview of third-party providers as well as their contents, together with links to their privacy policies which contain further instructions concerning data processing and possibility to appeal (so-called opt-out) which to some extent have already been mentioned here: Videos of the platform ‘YouTube’ of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.

Maps of the service ‘Google Maps’ of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.

Videos of the platform ‘Vimeo’ of the third-party provider Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy.

8. Scope measurement: Google Analytics

We use Google Analytics, a web analysis service of Google Inc. (‘Google’). Google uses cookies. The information generated by the cookie about usage of the online offer by the users is as a rule transferred to a server of Google in the USA and is stored there.

Google will use this information on our account in order to evaluate the usage of our online offers by the users to compile reports on activities within this online offer and to supply us with further services connected with the usage of this online offer and the web usage. Based on the processed data pseudonymous usage profiles of the users can be created.

We use Google Analytics only if IP anonymisation is activated. This means that the IP address of the users is shortened by Google within the member state of the European Union or in other Contracting States to the Agreement on the European Economic Area. Only in exceptional cases, the whole IP address is transferred to a Google server in the USA and is shortened there.

The IP address transmitted from the user browser is not brought together with other Google data. The users can prevent the storage of cookies by selecting the appropriate settings on their browser software. In addition, the users can prevent the collection of data generated by the cookies and data related to their usage of the online offer as well as processing of this data by Google by downloading the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information about the usage of data for advertising purposes by Google, configuration options and possibility to appeal You can find on the website of Google: http://www.google.com/policies/technologies/ads, http://www.google.de/settings/ads and http://www.google.com/ads/preferences/.

9. Google AdWords

We use the online advertising program ‘Google Adwords’ and the conversion racking in its framework in order to measure the success of the Google AdWords advertising. The cookie for conversion tracking is used if a user clicks one of the advertisements placed by Google.
There cookies lose their validity in 30 days and are not used personal identification. If this cookie has not yet expired when the user visits certain pages of this service, Google and the provider will be able to recognise that the user clicked the advertisement and was forwarded to this service. Each Google AdWords client receives another cookie. Therefore, it is impossible to keep track of cookies via the website of AdWords clients. The information obtained by means of the conversion cookies are intended to create conversion statistics for AdWords clients, which have opted for the conversion tracking. The clients find out the total number of users who clicked the advertisement and were forwarded to one of pages provided by a conversion tracking tag. However, they do not receive any information that can be used to identify the users. Based on the data processed pseudonymous usage profiles of the users can be created.

Users who do not want to participate in the tracking can deactivate the cookie of the Google conversion tracking via their internet browser in user settings or use opt-out possibilities provided by Google: http://www.google.com/policies/technologies/ads/.

10. Facebook remarketing

Within our online offer so-called ‘Facebook pixel’ of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, and if You are a EU resident by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (‘Facebook’). By means of the Facebook pixels, Facebook can determine whether the visitors of our online offer is the target audience for the display of advertisements, so-called ‘Facebook Ads’. We use the Facebook pixel accordingly in order to show our Facebook ads only such Facebook users who are interested in our Internet offer. That is, with the help of the Facebook pixel we want to ensure that our Facebook ads corresponds with the potential interest of the users and do not have an annoying effect. Furthermore, with the help of the Facebook pixel we can trace the effectiveness of Facebook advertisements for statistical and market research purposes by monitoring whether the user was forwarded to our website after clicking our Facebook advertisement (so-called ‘conversion’ and ‘visitor interaction’).

The Facebook pixel is integrated at every call-up of our web pages directly by Facebook and can store so-called cookie, i.e., a small file, on Your device. If You subsequently log on to Facebook or visit Facebook when logged on, the visiting our offer is recorded in Your profile. The data collected about You are anonymous for us and they do not give any indication of the personal identities of the users. However, the data is stored and processed by Facebook so that a connection to a particular user profile is possible. That means, the usage profiles based on user profiles can be created. The processing of the generated data by Facebook occurs within the framework of the Data Policy of Facebook. Therefore, You can receive further information about operation of remarketing pixels and about display of Facebook ads in the Data Policy of Facebook: https://www.facebook.com/policy.php.

You can object to the collection by the Facebook pixel and use of Your data for display by Facebook-Ads. To that end, You can call-up the webpage created by Facebook and follow the information about usage based advertising settings https://www.facebook.com/settings?tab=ads. The settings are made platform-independent, i.e., they are applied to all devices, such as desktops or mobile devices. Moreover, an objection is possible via the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/.

11. Use of Facebook-Plugins (Like-Button)

Our Internet site uses social plugins (‘plugins’) of the social network Facebook which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, and if You are a EU resident by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (‘Facebook’). The plugin can be recognised by one of Facebook logos (white “f” on a blue tile or a “thumbs up” symbol) or are indicated with the additional text “Facebook social plugin”.
The list and the look of the Facebook social plugins can be viewed here: http://developers.facebook.com/plugins.

When You call up a web page on our Internet site that includes a plugin of this type, Your browser establishes a direct connection with Facebook servers. Provided that so-called ‘double-click solution’ is applied (i.e., You will be explicitly asked for consent to activating the social plugins), You have to activate the switch area first prior to its execution. Only then, Your browser establishes a direct connection to the servers of Facebook. The content of the plugin is passed by Facebook direct to Your browser and integrated it into the website. This means that we have no influence over the extent of the data which Facebook obtains with the help of this plugin and we therefore inform You according to our information status:

Through integration of the plugin, Facebook obtains the information that You have called up the relevant page on our Internet site. If You are logged on to Facebook, Facebook can allocate the visit to Your Facebook account. I.e., based on the data used the usage profiles of users can be created. If You interact with the plugins by using the “Like-it-Button”, for example, or by posting a commentary, the information will be given direct to Facebook by Your browser and stored there. If You are not a Facebook member, there is still the possibility for Facebook to find out and store Your IP address.

For information on the purpose and extent of data capture and the further processing and use of data by Facebook, as well as Your rights in this regard and turn-off options for the protection of Your personal privacy, please refer to the Facebook data protection information: http://www.facebook.com/policy.php.

If You are a Facebook member and do not want Facebook to collect data about You via our Internet website and to link this with Your data stored on Facebook, You need to log off from Facebook before going to our website and delete cookies. Further settings and objections against data usage for advertising purposes are possible within Facebook profile settings: https://www.facebook.com/settings?tab=ads. The settings are made platform-independent, i.e., they are applied to all devices, such as desktops or mobile devices. Moreover, an objection is possible via the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/.

12. Revocation, change, rectifications and update

The users have the right, free of charge and upon request, to obtain the details of their personal data that have been stored. The contact data can be taken from the Imprint mentioned above. In addition, the users have the right to rectification of inaccurate data, revocation of consents, blocking and deletion of Your personal data as well as the right to file a complaint with a competent supervisory authority in case of assumption of an unlawful data processing.

The data we have stored are deleted as soon as they are not required for their indented purpose anymore and there is no legal retention requirements.

13. Changes to the Data Policy

We reserve the right to change the Data Policy in order to adapt it to any changes to legal situations or to rubinarealestate.com as well as data processing. Therefore, the users are asked to inform themselves regularly of the content of the Data Policy, in particular if they again communicate personal Information.