Privacy Policy

We take your privacy very seriously and treat your personal data confidentially and in accordance with the legal requirements. Since new technologies and the continuous development of this website may result in changes to this Privacy Policy, we recommend that you re-read it at regular intervals. In addition to this Privacy Policy, other declarations relating to data protection may regulate specific issues.

This Privacy Policy is aligned with the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union (EU), it is relevant to us. The Swiss Data Protection Act (DPA) is strongly influenced by EU law, and companies outside the EU or the European Economic Area (EEA) have to comply with the GDPR under certain circumstances. Therefore, we have aligned this Privacy Policy with their standard.

For the purposes of this Privacy Policy, personal data means any information relating to an identified or identifiable individual. If you provide us with personal data of other persons (e.g. family members or work colleagues), please make sure that they are aware of this Privacy Policy and only share their personal data with us if you are allowed to do so and this personal data is correct.

Name and contact details of the party responsible for processing

This privacy information applies to data processing by us as the responsible party:

Ella Media AG;

Metallstrasse 9a; 6300 Zug; Switzerland; verwaltung@ella-group.io

For further information about our company, please refer to the imprint on our website https://www.ella-group.io/imprint/

Make a request to the data subject

Use of the Data Subject Request Tool (DSR) for the management of data subject requests

1. Scope of processing personal data

We use functionalities of the data protection plug-in „DSR“ of DataCo GmbH, Dachauer Str. 65, 80335, Munich, Bavaria, Germany (hereinafter referred to as: DataCo).

By using the button „Submit Data Subject Request“, all visitors of our website have the opportunity to make use of their data subject rights. To do so, you specify your relationship to our company, which data subject right you wish to exercise, provide further optional information and, if necessary, identify yourself with further characteristics. The data subject request will then be processed by us.

The following personal data will be processed by DataCo:

First and last name
Relationship to the controller (employee, customer, interested party, etc.)
E-mail address
Further voluntarily communicated personal data

For further information on the processing of data by DataCo, please click here: https://www.dataguard.com/privacy-policy

In addition, to ensure technical functionality, logfiles may be forwarded to DataCo GmbH, which include the following:

Browser type and version used
The user’s operation system
The user’s internet service provider
The user’s IP address
Date and time of access
Websites from which the user’s system made the request

2. Purpose of the data processing

The use of DSR serves to protect the data protection rights of our website visitors. We enable you to make use of your data subject rights and to contact us quickly and easily.

3. Legal basis for data processing

The legal basis for the use of the DSR tool and the processing of corresponding data is your declaration of consent in accordance with art. 6 para. 1 s. 1 lit. a GDPR.

The legal basis for the use of the logfiles is our legitimate interest in ensuring the technical functionality of the tool according to art. 6 para. 1 s. 1 lit. f GDPR.

4. Duration of storage

Data will be stored for as long as necessary to fulfil the purposes described in this privacy policy or as required by law.

5. Objection and removal

The user has the possibility to revoke the consent to the processing of their personal data or object the processing of logfiles at any time by contacting the data controller by mail or by using the DSR tool.

Contact details of the data protection officer

The data protection officer of the responsible party is:
DataCo GmbH
Dachauer Straße 65
80335 Munich
Germany
+49 89 7400 45840
www.dataguard.de

Collection and storage of personal data as well as mode and purpose of their use

When visiting the website

When you visit our website, the browser used on your terminal device automatically sends information to our website’s server. This information is stored temporarily (for a maximum of seven days) in a so-called log file. The following information is collected automatically and stored until their automated removal:

Website visited
IP address of the requesting computer,
Date and time of access,
Name and URL of the file accessed,
Source or link with which you accessed the page
Browser used
Operating system used by your computer and the name of your access provider
Amount of data sent in bytes

The aforementioned data are processed by us for the following purposes:

Ensuring a smooth connection setup of the website,
Ensuring comfortable use of our website and its optimization,
Ensuring system security and stability, and
For further administrative purposes

The legal basis for data processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. By no means do we use the collected data for the purpose of drawing conclusions about your person.

In addition, we use cookies and analysis services when you visit our website. You can find more details under points 5 and 6 of this Privacy Policy.

b) When using our contact form

There is a contact form on our website that can be used to get in touch with us electronically. In doing so, the data you enter in the input mask is transmitted to us and stored. We may request the following data:

Gender
Name, first name, address of residence, nationality, company
E-mail address, telephone number
Date and time of contact
Reason for getting in touch & free text

When you send a message, the following data is also stored:

Your IP address
Date and time of sending

Data processing for the purpose of contacting us is carried out in accordance with Art. 6 Para. 1 lit. a GDPR on the basis of your voluntarily given consent. The personal data collected by us through the contact form will be automatically deleted after your request has been completed by us.

c) When registering for online subscription

We use software on our website that allows users to register as investors. By selecting the plugin ‘Start the subscription here’ you will be asked to enter the following data in the input mask, which will be transmitted to us and stored:

Title
First name, last name, address of residence, nationality
Power of representation and domicile
E-mail address, telephone number
Retrieval and acknowledgement of the general terms and conditions
Retrieval and acknowledgement of the data protection regulations
Consent to receive e-mails for advertising purposes (optional)
Desired subscription amount
Date of birth

The legal basis for data processing for the purpose of online subscription is Art 6 (1) lit b, c and f GDPR. Our legitimate interest is to obtain new subscribers or investors for our company.

d) When an e-mail is sent, the personal data transmitted with the e-mail, including the user’s e-mail address, is stored. This serves to process and respond to your inquiry, e.g. to answer questions in connection with products, company investments or applications, based on Art. 6 para. 1 lit. a, b or f GDPR.

e) In order to process the subscription, please also send us a copy of your ID card. The following data will be stored in addition to those listed under c):

Place of birth
Place of issue
Issuing authority
ID card number

The data is collected in order to clearly establish the identity of the contracting party and to fulfill legal obligations, in particular to prevent money laundering and to establish identity, for which purposes the data listed under c) and e) may also be forwarded to banks or external consultants with whom Ella Media AG cooperates, or to state authorities. The legal basis for this is Art. 6 para. 1 lit b and c.

Disclosure of data

We do not transfer your personal data to third parties for purposes other than those listed below.

We only pass on your personal data to third parties if:

you have given your explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR,
the disclosure is necessary for the assertion, exercise or defense of legal claims pursuant to Art. 6 (1) (f) GDPR and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
in the event that there is a legal obligation for disclosure pursuant to Art. 6 (1) c GDPR, as well as
this is legally permissible and necessary for the processing of contractual relationships with you according to Art. 6 para. 1 lit. b GDPR (e.g. verification of the identity of the investor by the bank involved in the processing of the contract).

Duration of personal data storage

We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the period during which claims can be asserted against our company (i.e. in particular during the statutory limitation period) and to the extent that we are otherwise required to do so by law or legitimate business interests require it (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less apply in principle

Cookies

We use cookies on our site. These are small files that are automatically created by your browser and stored on your end device (laptop, tablet, smartphone or similar) when you visit our site. Cookies do not cause any damage to your end device and do not contain viruses, Trojans or other malware.

In the cookie, information is stored that arises each time when the specific end device is used. This does not mean, however, that we gain direct knowledge of your identity.

The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again. The data processed by such cookies are necessary for the aforementioned purposes to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) lit. f GDPR.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer (see section 5). These cookies enable us to automatically recognize that you have already been to our site when you visit again. These cookies are automatically deleted after a defined period of time. When you visit our website, you will be informed by a pop-up window about the use of cookies for analysis, referred to the data protection information and asked to give your consent.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, deactivating cookies may mean that you cannot use all the functions of our website.

Analysis and tracking tools

The tracking measures listed below are carried out on the basis of Art. 6 (1) lit. f GDPR. With the tracking measures we want to ensure a needs-based design and the ongoing optimization of our website. On the other hand, we use tracking measures to statistically record the use of our website and evaluate it for the purpose of optimizing our offer. These interests are to be regarded as legitimate within the meaning of the aforementioned provision.

The respective data processing purposes and data categories can be found in the corresponding tracking tools.

a) Google Analytics

For the purpose of demand-oriented design and ongoing optimization of our pages, we use Google Analytics, a web analytics service provided by Google Inc. (https://www.google.de/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, US; hereinafter ‘Google’). In this context, pseudonymized usage profiles are created and cookies (see under section 4) are used. The information generated by the cookie about your use of this website, such as the

IP address of the user’s calling system
Website visited
Website from which the user has accessed the website
subpages accessed from the website
length of time spent on the website
frequency with which the website is accessed
demographic and geographical information (if transmitted)
technical information about the access device and software used

are usually transferred to a Google server in the US and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to the use of the website and the Internet for the purposes of market research and demand-oriented design of these Internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so identification is not possible (IP masking).

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be set, which prevents the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found, for example, in the Google Analytics help section (https://support.google.com/analytics/answer/6004245?hl=en).

b) Google Tag Manager

We use the Google Tag Manager (https://www.google.com/intl/en/tagmanager/) of Google Ireland Ltd, Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter referred to as: Google). With the Google Tag Manager, tags of Google’s services and of third-party providers can be managed, bundled and embedded on an online presence. Tags are small code elements on an online presence that are used, among other things, to measure visitor numbers and behavior, to record the impact of online advertising and social channels, to use remarketing and targeting, and to test and optimize online presences. When a user visits the online presence, the current tag configuration is sent to the user’s browser. It contains instructions on which tags to trigger. Google Tag Manager triggers other tags, which in turn may collect data. Information on this can be found in the section on the use of the corresponding services in this Privacy Policy. Google Tag Manager does not access this data.
Further information on Google Tag Manager can be found at https://www.google.com/intl/de/tagmanager/faq.html and in Google’s privacy policy: https://policies.google.com/privacy?hl=en

The purpose of the processing of personal data lies in the collected and clear management and efficient integration of third-party services. The legal basis for the processing of the personal data of users is in principle the consent of the user according to Art. 6 para. 1 p.1 lit. a GDPR.

Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google by deleting parts of the IP address and cookie information after 9 and 18 months respectively.

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

You can prevent the collection as well as the processing of your personal data by Google by preventing the storage of third-party cookies on your computer, using the ‘Do Not Track’ function of a supporting browser, disabling the execution of script code or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.

You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
You can deactivate the use of your personal data by Google using the following link:
https://adssettings.google.com
For more information on opt-out and removal options regarding Google, please visit:
https://policies.google.com/privacy?gl=DE&hl=en

c) HubSpot

We use functions of HubSpot Inc, 2nd Floor, 25 First Street, Cambridge, MA 02141, US (hereinafter referred to as: HubSpot). This is an integrated software solution that we use to cover various aspects of our online marketing. These include: Email marketing (newsletters as well as automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (traffic sources, hits, etc.), contact management (user segmentation & CRM), landing pages, creating ad target groups and contact forms. Cookies from HubSpot are stored on your end device in the process. As a result, personal data can be stored and evaluated, especially the user’s activity (which pages have been visited and which elements have been clicked), device and browser information (the IP address and the operating system), data about the advertisements displayed (which advertisements were displayed and whether the user clicked on them) and also data from advertising partners (pseudonymized user IDs).

For more information on the processing of data by HubSpot, please click here:
https://legal.hubspot.com/privacy-policy

The use of the HubSpot plugin serves exclusively to optimize our marketing. The legal basis for the processing of the users’ personal data is in principle the user’s consent according to Art. 6 para. 1 p.1 lit. a GDPR. Your personal information will be stored for as long as necessary to fulfill the purposes described in this privacy policy or as required by law, e.g. for tax and accounting purposes.

You can prevent the collection as well as the processing of your personal data by HubSpot by preventing the storage of third-party cookies on your computer, using the ‘Do Not Track’ function of a supporting browser, disabling the execution of script code or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) on your browser.

You can find more information about objection and removal options regarding HubSpot at: https://legal.hubspot.com/de/privacy-policy.

We use functionalities of the analysis plugin Microsoft Clarity of Microsoft Corporation, One Microsoft Way, 98052, Redmond, Washington, US and its representative in the European Union Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter: Microsoft).

Microsoft Clarity provides us with insights into the use of our website and the interaction of website users with our content in the form of heat maps as an analysis tool.

The following personal data is processed by Microsoft as a result:

Device and browser information
User behavior on the website
Web pages visited

In the process, data is transferred to Microsoft servers in the US. To ensure appropriate guarantees for the protection of the transfer and processing of personal data outside the EU, so-called EU standard contractual clauses (Art. 46 para. 2 p. 1 lit. c GDPR) have been agreed with Microsoft.
For more information on the processing of data by Microsoft, please click here:
https://privacy.microsoft.com/en-us

https://docs.microsoft.com/en-us/clarity/faq

The use of Microsoft Clarity serves to analyze website interactions. The legal basis for the processing of users’ personal data is in principle the user’s consent in accordance with Art. 6 para. 1 p.1 lit. a GDPR. Your personal information will be stored for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

You can prevent the collection as well as the processing of your personal data by Microsoft by preventing third-party cookies from being stored on your computer, by using the ‘Do Not Track’ function of a supporting browser, by disabling the execution of script code or by installing a script blocker such as NoScript (https://noscript.net) or Ghostery (https://www.ghostery.com) on your browser.

For more information on revocation and removal options regarding Microsoft, please visit:

https://www.privacy.microsoft.com/en-us/privacystatement

Social Media Plug-ins

We use social plug-ins of the social networks Facebook, Twitter and Instagram on our website on the basis of Art. 6 (1) lit. f GDPR in order to make our company more widely known. The underlying promotional purpose is to be regarded as a legitimate interest within the meaning of the GDPR. The responsibility for data protection-compliant operation is to be ensured by their respective providers.

a) LinkedIn

We use the option of corporate presences on professionally oriented networks. We maintain a corporate presence on the following profession-oriented networks:

LinkedIn:

LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland

XING:

XING SE, Dammtorstraße 30, 20354 Hamburg, Germany

On our site, we provide information and offer users the opportunity to communicate.

The corporate presence is used for job applications, information/PR and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate presence. For more information, please refer to the privacy policy of:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

b) XING:

https://privacy.xing.com/en/privacy-policy

If you carry out an activity on our corporate presence (e.g. comments, posts, likes, etc.), your personal data (e.g. name or photo of your user profile) could be made public.

The legal basis for the processing of your data in connection with the use of our corporate presence is Art.6 Abs.1 S.1 lit. f GDPR. Our corporate presence serves to inform users about our services. In doing so, every user is free to publish personal data through activities. We store your activities and personal data published via our corporate presence until you revoke your consent. In addition, we comply with the statutory retention periods.

You can object at any time to the processing of your personal data that we collect in the course of your visit to our corporate presence and assert your data subject rights listed under IV. of this Privacy Policy. To do so, please send us an informal email to the email address stated in this Privacy Policy.

ou can find more information on objection and removal options here:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv
XING:

https://privacy.xing.com/en/privaca-policy

Data subject rights

You have the right:

In accordance with Art. 15 GDPR, to request information about your personal data processed by us. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details;
pursuant to Art. 16 GDPR, to request the correction of incorrect or incomplete personal data stored by us without undue delay;
pursuant to Art. 17 GDPR, to request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;
pursuant to Art. 18 GDPR, to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defense of legal claims or you have objected to the processing pursuant to Art. 21 GDPR;
pursuant to Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another responsible party;
in accordance with Art. 7 (3) GDPR, to revoke your consent once given to us at any time. This has the consequence that we may no longer continue the data processing, which was based on this consent, in the future; and
complain to a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose (in Switzerland, the competent data protection authority is the Swiss Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch)).

Right of objection

If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) f GDPR, you have the right to object to the processing of your personal data pursuant to 21 GDPR, provided that there are grounds for doing so that arise from your particular situation or if the objection is directed against direct marketing. In the latter case, you have a general right of objection, which is implemented by us without specifying a particular situation.

If you would like to exercise your right of revocation or objection, please send an e-mail to: verwaltung@ella-group.io.

Please note, however, that we reserve the right to assert the restrictions provided for by law on our part, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or require it for the assertion of claims. If costs are incurred by you, we will inform you in advance.

The exercise of your data subject rights also generally requires that you clearly prove your identity (e.g. by means of a copy of your ID card, if your identity is otherwise not clear or cannot be verified).

Furthermore, every data subject has the right to enforce his or her claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

Actuality and change of this Privacy Policy

This Privacy Policy is currently valid and was last updated in August 2022.

Due to the further development of our website and offers on it or due to changed legal or regulatory requirements, it may be necessary to change this Privacy Policy. You can access and print the current Privacy Policy at any time on the website under https://www.ella-group.io/data-privacy/.