We operate our websites in accordance with the principles set out below:
We commit ourselves to comply with the legal provisions on data protection and strive to always take into account the principles of data avoidance and data minimization.
a) The controller
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states of the European Union as well as other data protection regulations is
WTS Advisory AG
Königstr. 27
70173 Stuttgart
T +49 (0) 711 6200749-0
F +49 (0) 711 6200749-99
info-advisory@wts.de
WTS Advisory is represented by the Management Board: Nikolaus Färber.
WTS Advisory operates the website as the sole responsible party.
It also uses the website to provide information about all companies belonging to the WTS Advisory Group and about FAS Lease AG.
b) The data protection officer
You can contact the data protection officer of the controller as follows
SiDIT GmbH, Langgasse 20, 97261 Güntersleben, info@sidit.de
We have designed our privacy policy in accordance with the principles of clarity and transparency. However, if there are any uncertainties regarding the use of various terms, the corresponding definitions can be viewed here.
a) Processing of personal data in accordance with the GDPR
We only process your personal data, such as your surname and first name, your email address and IP address, etc., if there is a legal basis for doing so. According to the General Data Protection Regulation, the following regulations in particular come into consideration here:
However, we will always point out the legal basis for the processing of your personal data at the relevant points in this privacy policy.
b) Consent of the custodian according to Art. 8 para. 1 sentence 2 alt. 2 GDPR
A legal guardian must consent to all data processing on this website for which the consent of a minor who has not yet reached the age of 16 is required.
Information on the individual data processing operations, their purposes and the categories of data concerned for which the consent of the data subject is required can be found in the privacy policy.
The disclosure of personal data also constitutes processing within the meaning of section 3 above. However, we would like to take this opportunity to inform you separately about the issue of disclosure to third parties. The protection of your personal data is very important to us. For this reason, we are particularly careful when it comes to passing on your data to third parties.
Data is therefore only passed on to third parties if there is a legal basis for the processing. For example, we pass on personal data to persons or companies who work for us as processors in accordance with Art. 28 GDPR. A processor is anyone who processes personal data on our behalf - i.e. in particular in a relationship of instruction and control with us
In accordance with the requirements of the GDPR, we conclude a contract with each of our processors in order to oblige them to comply with data protection regulations and thus ensure comprehensive protection of your data.
Your personal data will be deleted by us if they are no longer necessary for the purposes for which they were collected or otherwise processed, if the processing is not necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
This website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as the requests you send to us as the website operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We use cookies on our website. Cookies are small data packets that your browser automatically creates and that are stored on your end device when you visit our website. These cookies are used to store information in connection with the end device used.
When cookies are used, a distinction is made between technically necessary cookies and "other" cookies. Technically necessary cookies are those that are absolutely necessary in order to provide an information society service that you have expressly requested.
a) Technically necessary cookies
In order to make the use of our website more convenient for you, we use technically necessary cookies, which may be so-called session cookies (e.g. language and font selection, shopping cart, etc.), consent cookies, cookies to ensure server stability and security or similar. The legal basis for the cookies results from Art. 6 para. 1 sentence 1 lit. f) GDPR, our legitimate interest in the error-free operation of the website and the interest in providing you with our services in an optimized manner.
b) Other cookies
Other cookies include cookies for statistical, analytical, marketing and retargeting purposes.
We use these cookies for you on the basis of your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR.
You can revoke your consent to the use of cookies at any time.
We inform you that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
To do this, you can either edit your cookie settings on our website, deactivate the use of cookies in your browser settings (whereby this may also restrict the functionality of the online offer) or set an opt-out for the corresponding service in individual cases.
We will inform you of the legal basis on which this data is processed for the respective services within the privacy policy.
To obtain consent for the cookies we use, we use the cookie banner CCM19 from the service provider Papoo Software & Media GmbH
Auguststr. 4, 53229 Bonn, Germany. This cookie itself sets a so-called consent cookie in order to query and process the respective consent status. This consent cookie is technically necessary and is therefore used on the basis of our legitimate interest in accordance with Art. 6 Para. 1 S.1 lit. f GDPR, § 25 Para. 1 TTDSG.
For the use of some services of the Google/Alphabet Group, we use the so-called Google Consent Mode V2 in Basic Mode. Details on this consent mode can be found on the Google website at https://developers.google.com/tag-platform/security/guides/consent?hl=de&consentmode=advanced.
The use of Consent Mode is technically necessary and is therefore used on the basis of our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
a) External hosting
Our website is hosted by Fujitsu Services GmbH, Gladbecker Str. 7, 40472 Düsseldorf, Germany. For this reason, all personal data collected on our website is stored on the servers of our hoster, unless an external service of a third party is integrated. This may be the IP address, your e-mail address, communication data or similar. You can find out which specific personal data is involved in the individual functions and services explained by us below. If we use an external service from a third party, this will be made clear in the description of the respective service or tool.
The hoster only processes your data on our instructions and insofar as this is necessary to fulfill the services on the website. The hoster does not process the data for its own purposes. We have concluded an order processing contract with the host.
b) When visiting the website
When you visit our website, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected without any action on your part and stored until it is automatically deleted
The aforementioned data is processed by us for the following purposes
Data that can be used to identify you personally, such as your IP address, will be deleted after 7 days at the latest. If we store the data beyond this period, this data is pseudonymized so that it can no longer be assigned to you.
The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. Under no circumstances do we use the data collected for the purpose of drawing conclusions about your person.
c) Newsletter
Content of the newsletter and registration data
We will only send you our newsletter and carry out statistical surveys and analyses and log the registration process if you order it from us and have given your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, § 25 para.1 TTDSG.
The contents of the newsletter are described in detail when you register for the newsletter. To subscribe to the newsletter, it is sufficient to provide your email address. If you provide further voluntary information, such as your name and/or gender, this will only be used to personalize the newsletter addressed to you.
Double opt-in and logging
For security reasons, we use the so-called double opt-in procedure to register for our newsletter so that no one can register with other people's e-mail addresses. After registering for our newsletter, you will therefore first receive an e-mail asking you to confirm your registration. Your registration only becomes effective once you have confirmed it.
Furthermore, your registration for the newsletter will be logged. The logging includes the storage of the time of registration and confirmation, the data you provide and your IP address. If you make changes to your data, these changes will also be logged.
Cancellation
If you no longer wish to receive our newsletter, you can revoke your consent at any time for the future. To do so, you can click on the unsubscribe link at the end of each newsletter or send us an email to the following email address: info-advisory@wts.de
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Use of CleverReach
We use the CleverReach email tool (CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany) to send our newsletter.
For this purpose, the data you provide will be forwarded to CleverReach and processed by it. This tool enables us to analyze how the newsletters are opened and used.
We have concluded an order processing contract with CleverReach. CleverReach does not obtain the right to pass on your data.
Further information on CleverReach's data protection can be found here. [http://www.cleverreach.de/datenschutz/]
We use Friendly Captcha (hereinafter "Friendly Captcha") on this website. The provider is Friendly Captcha GmbH, Am Anger 3-5, 82237 Woerthsee, Germany. When you send a puzzle request, we collect the following log data via our processor Friendly Captcha:
We store an anonymized counter per IP address for dynamic scaling of puzzle difficulty on the Edge network to detect malicious users and minimize blocking of legitimate users. This data is stored separately from the rest of the data and cannot be associated with specific websites. We anonymize the IP addresses via one-way hashing so that they cannot be personally identified. You can find more information on this at: https://friendlycaptcha.com/legal/privacy-end-users/.
The service is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR for the above-mentioned purposes.
e) Contact form
We provide you with a form on our website so that you have the opportunity to contact us at any time. To use the contact form, it is necessary to provide a name for a personal salutation and a valid e-mail address so that we know who sent the request and can process it.
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there and your IP address, will be processed in accordance with Art. 6 para. 1 sentence 1 lit. b and f GDPR to carry out pre-contractual measures in response to your inquiry or to safeguard our legitimate interests, namely to carry out our business activities.
The inquiries and the associated data will be deleted no later than 3 months after receipt, unless they are required for a further contractual relationship.
f) Event registration form
We provide you with forms on our website to register for events and webinars. To use the form, it is always necessary to provide a name for a personal salutation and a valid e-mail address so that we know who sent the request and can process it. It may also be necessary to provide an address or other contact details. You will be informed on the form whether this is mandatory or voluntary information.
If this is mandatory information, your data will be processed in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the implementation of pre-contractual measures that are carried out at your request or to safeguard our legitimate interests, namely to carry out our business activities. If the information provided is voluntary, it will be processed on the basis of our legitimate interest in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.
g) Application form
We provide you with a form on our website that you can use to apply for a job with us. Your personal data from the application will be processed in accordance with our data protection information for applicants.
The use of this form is based on our legitimate interest in a simple and secure transmission of your application documents, Art. 6 para. 1 sentence 1 lit. f) GDPR.
We use the workday software from The King's Building, 152-155 Church Street, Dublin 7, D07 A0TN, Ireland. We have concluded an order processing contract with them.
h) Google Tag Manager
We use the Google Tag Manager from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. Google Tag Manager is an administration and management tool in which other tracking and/or statistics tools can be centrally managed and played out.
When you visit our website and give your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR, Google Tag Manager collects and processes your IP address, which may also be transferred to the USA. However, Google Tag Manager itself does not create any user profiles or analyses.
We have concluded an order processing contract with Google.
The Google privacy policy can be found here. [https://www.google.com/policies/privacy/?hl=de]
We use the analysis and tracking tools listed below on our website. These serve to ensure the continuous optimization of our website and to design it to meet your needs.
We use these tools on the basis of your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. You can withdraw your consent at any time by changing the cookie settings. Processing remains lawful until you withdraw your consent.
The respective data processing purposes and data categories can be found in the corresponding tools. We would like to point out that we have no influence on whether and to what extent the service providers carry out further data processing.
a) Google Analytics
We use Google Analytics on our website, a web analysis service from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as "Google").
Google Analytics uses cookies in this context (see section 7). The information generated by the cookie about your use of this website, such as
are usually transmitted to a Google server in the USA and stored there.
Your IP address is automatically anonymized by Google before it is recorded via EU domains and servers. There is therefore no logging or storage of your IP address.
Google will use this information on our behalf to evaluate your use of our website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
We have concluded an order processing contract with Google.
Please click here for an overview of data protection at Google. [https://support.google.com/analytics/answer/6004245]
b) Google Remarketing
We use the remarketing function of Google Analytics to target advertising campaigns - including Google AdWords campaigns - to visitors to our website.
Based on your previous visits to our website, you will be presented with relevant advertisements when you visit other websites in the Google Display Network.
The DoubleClick cookie enables Google to show us and other third-party providers targeted advertising that corresponds to the interests determined on the basis of your previous visits to our website and/or other websites. This advertising may be displayed on Google websites and/or other operators of the Google advertising network. We also use the Google Analytics advertising functions to analyze the effectiveness of our own advertising campaigns.
If you have agreed in your Google account that your web and app browsing history will be linked by Google to your Google account and information from your Google account will be used to personalize ads, Google will use data from you together with Google Analytics data to create target group lists for cross-device remarketing. For this purpose, Google Analytics first collects Google-authenticated IDs for you as a user on our website, which are linked to your Google account. Google Analytics then temporarily links these IDs with Google Analytics data in order to optimize our target groups.
We have concluded a data processing agreement with Google.
Please click here for an overview of data protection at Google. [https://support.google.com/analytics/answer/6004245]
c) Google Ads conversion tracking
We use Google Ads, an online advertising program from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. Conversion tracking is also used. With this tool, Google Ads places a cookie on your device when you access our website via a Google ad.
The cookie is not used for personal traceability. If you visit our website as a user and the cookie is still working, we and Google will recognize that you clicked on the corresponding ad and were redirected to our site. A different cookie is assigned to each Google Ads customer. This means that cookies cannot be tracked via the websites of Ads customers.
The data collected by conversion cookies is used to create conversion statistics for Ads customers. As Google Ads customers, we can find out the total number of users who responded to our ad and were then redirected to a website that was tagged with a conversion tracking tag. This allows us to recognize the success of individual advertising measures. During this process, we do not receive any information with which we could personally identify you as a user.
When using Google Ads, your browser automatically establishes a direct connection with the Google server and, if you have a Google account and are logged into it, can assign the visit to your account. If you do not have a Google account, Google will assign you a unique identifier. We have no influence on what other data Google collects and stores.
We have implemented Google's "extended conversions" function on our website. This means that data we collect ourselves, such as email address, name, address or telephone number, is recorded in conversion tracking tags. These are then sent to Google in hashed form, where they are used to match our existing customers with Google accounts. You can find more information about this function at https://ads.google.com/intl/de_de/home/privacy/solutions/enhanced-conversions-for-web/
We have concluded an order processing contract with Google.
You can find out more about Google's privacy policy at http://www.google.de/policies/privacy/.
d) Google AdSense
We use the Google AdSense service from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) on our website to integrate advertisements.
Google AdSense uses cookies. These are files that enable Google to analyze the data of your use of our website by storing them on your device. Google AdSense also uses web beacons, invisible graphics that enable Google to analyze clicks on our website, the traffic on it and similar information.
The information obtained via cookies and web beacons, your IP address and the delivery of advertising formats are transmitted to a Google server located in the USA and stored there. Google may pass this collected information on to third parties if this is required by law or if Google commissions third parties to process the data. However, Google will not merge your IP address with the other stored data.
We have concluded an order processing contract with Google.
You can find out more about Google's data protection provisions at
http://www.google.de/policies/privacy/.
e) Google Optimize
We use the web analysis and optimization service "Google Optimize" on our website, which is provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Optimize is a sub-service of Google Anlaytics.
Google Optimize uses cookies in this context (see section 7). The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
However, as we have activated IP anonymization on our website, your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
We use the Google Optimize service to increase the attractiveness, content and functionality of our website by displaying new functions and content to a percentage of our users and statistically evaluating the change in usage.
We have concluded an order processing contract with Google.
Please click here for an overview of data protection at Google. [https://support.google.com/analytics/answer/6004245]
YouTube
We embed videos from YouTube, which is operated by Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), into our website as part of iFrame and/or via a plug-in. As part of embedding the videos, we have activated YouTube's extended data protection mode.
If you play a YouTube video during your visit, a connection to the YouTube servers is established and the YouTube server is informed which of our pages you have visited. This allows YouTube to associate your surfing behavior directly with your personal profile. You can prevent this by logging out of your member account before visiting our website. In addition, YouTube sets various cookies when the service is started in order to improve the services it offers and to prevent misuse.
Further information on the handling of user data and the cookies set can be found in YouTube's privacy policy at: https://www.google.de/intl/de/policies/privacy
By integrating YouTube, Google Fonts and Google Photos are also dynamically reloaded by Google without the website operator or visitor actively determining this. These services are integrated via a server call, usually a Google server in the USA. This may result in the following being transmitted to the server and stored by Google
You can find more information in Google's privacy policy, which you can access here:
The legal basis results from the consent you have given in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent at any time by changing the cookie setting on our website.
You have the following rights:
a) Information
In accordance with Art. 15 GDPR, you have the right to request information about your personal data processed by us. This right to information includes information about
b) Rectification
In accordance with Art. 16 GDPR, you have the right to obtain from us without undue delay the rectification of inaccurate or incomplete personal data stored by us.
c) Erasure
In accordance with Art. 17 GDPR, you have the right to demand that we erase your personal data without undue delay, unless further processing is necessary for one of the following reasons
d) Restriction of the processing
In accordance with Art. 18 GDPR, you can request the restriction of the processing of your personal data for one of the following reasons
e) Notification
If you have requested the rectification or erasure of your personal data or a restriction of processing in accordance with Art. 16, Art. 17 or Art. 18 GDPR, we will inform all recipients to whom your personal data has been disclosed, unless this proves impossible or involves a disproportionate effort. You can request that we inform you of these recipients.
f) Transmission
You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format.
You also have the right to request the transfer of this data to a third party, provided that the processing is carried out using automated procedures and is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR.
g) Revocation
In accordance with Art. 7 para. 3 GDPR, you have the right to revoke your consent to us at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In future, we may no longer continue the data processing that was based on your withdrawn consent.
h) Complaint
In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR.
i) Objection
If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying the particular situation. If you wish to exercise your right of revocation or objection, simply send an email to info-advisory@wts.de
j) Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
i. is necessary for the conclusion or performance of a contract between you and us
ii. is authorized by European Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests
iii. is made with your express consent
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in i) and iii), we shall take reasonable steps to safeguard the rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on our part, to express your point of view and to contest the decision.
If we change the privacy policy, this will be indicated on the website.
Status: 20.06.2024
Your contact to us
Do you have any questions about our services or WTS Advisory? We look forward to your message or your call!