Data controller and contact details
The data controller for the data processing on this website is LINUS GmbH (“Linus”, “we”, “us”, “our”). You can reach us at our postal address, Karl-Marx-Allee 3, 10178 Berlin or by email at firstname.lastname@example.org.
Scope of application
Data processing and legal basis for the processing
The Website can be visited without any personal registration. In this case, only the internet connection data which your browser automatically sends to our server is processed. This data comprises your IP address and other usage data (e.g. date and time of access, name of the page visited, transmitted data volume and the requesting ISP). This information is needed in order to enable you to use our Website, for example by adjusting the Website to the requirements of your device. The legal basis is Art. 6 (1) first sentence (b) of the GDPR, to the extent the data processing is necessary for the provision of our service. Any data processing beyond that is based on Art. 6 (1) first sentence (f) GDPR. We have a legitimate interest in ensuring the security and effective use of our Website.
The automatically collected personal data is stored for twelve months and then immediately deleted.
In connection with certain services and offerings we might also ask you to provide personal data, such as name or email address and/or other personal information. Required information in such circumstances is always marked as mandatory. Without this information, it may be impossible for us to provide the desired service or answer any enquiries from you. In the following, we provide an overview of the associated processing activities and legal bases.
If you contact us - e.g. by email - the personal data you communicate to us in the email is stored and processed by us. This would normally be your name and your email address or any other information supplied by you. This data is stored and used solely for the purpose of responding to your enquiry or making contact with you as well as the associated technical administration. The purpose of the processing of this data is to perform a contractual agreement or take pre-contractual steps (Art. 6 (1) first sentence (b) GDPR) and/or we have a legitimate interest in the processing without this being overridden by any conflicting interests of yours, because the processing of these enquiries is in our mutual interests (Art. 6 (1) first sentence (f) GDPR).
Registration as an investor
You have the possibility of registering on our Website as an investor. For the purposes of this registration, we process the following personal data of yours:
• First name and surname
• Email address
• Telephone number
• Company name
• Type of business
• Address of business
We use the so-called double-opt-in method, i.e. your registration is only completed once you have confirmed your application by clicking on the link contained in the confirmation email sent to you for this purpose. If you do not provide this confirmation, your application will be deleted from our database.
When a registered user visits our login area, we process, in addition to the usage data mentioned above (see Section 3 below), information the date of the last login, on the documents you download and the project pages you open.
In the registration process, we will, at our discretion, perform a verification check (e.g. personal ID of the representative or the investor; identification of persons holding significant participations) and collect information on financial assets (e.g. proof of sufficient funds; verification of investor’s knowledge about investments (where relevant); bank accounts (where relevant); extract from the commercial register (where relevant)). When you make an investment, we also process information related to your bank account, the date and the amount of the investment. In the case of registered users, the date and amount of the investment will also be processed in their profile.
The legal basis for this processing of data is Art. 6 (1) first sentence (b) GDPR. This personal information is stored by us for the duration of the contractual relationship. The storage of data in your profile continues until you delete the data via the profile or effect the deletion of your entire profile, unless statutory data retention provisions exist.
Provided that you have given us the relevant consent, we use your personal data, including your name and email address and your mobile telephone number (where applicable), to send you occasional notifications by email and SMS, e.g. in relation to new projects or quarterly reports. The granting of consent is voluntary. You may revoke your consent at any time with effect for the future. The legal basis is Art. 6 (1) first sentence (a) GDPR.
You can use our Website to find out about open positions at LINUS Capital. You can send your application to us via email.
In the course of the application process, the personal data sent by you (including your name, contact details, qualifications and other application documents) will be processed for the purposes of reviewing your application and deciding whether or not to offer you the position. Without certain personal information an application cannot be considered. Your application documents and the personal data contained in them will be passed on internally to the employees responsible for making the decision. The legal basis is Sec. 26 (1) BDSG (German Federal Data Protection Act). We process information voluntarily provided in the course of your application on the basis of Sec. 26 BDSG in conjunction with Art. 6 (1) first sentence (a) GDPR.
If you become employed by us, we will continue to process the data in order to perform the employment contract (Sec. 26 (1) BDSG).
If you do not become employed by us, your personal data will be deleted within six months of the end of the application process. If you give your consent, we will continue to store your data in order to inform you about positions which become open in the future. Legal basis is Sec. 26 (1) BDSG in conjunction with Art. 6 (1) first sentence (a) GDPR.
We use some cookies which enhance the usability of our Website, e.g. by storing your settings, and which are necessary for the trouble-free use of our Website. In addition, your user information (e.g. name, email address, investments, user role) necessary for the functioning of the website is accessed in the internal area of the Website. At the end of a browser session, these cookies are automatically deleted. The legal basis for the use of such cookies is Art. 6 (1) first sentence (b) GDPR.
This Website uses functions from the web analysis service, Google Analytics. The provider of that service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses “cookies” (see above). The information generated by the cookie about your use of this Website will normally be transmitted to a server in the USA and stored there. The legal basis for the storage of Google Analytics cookies is Art. 6 (1) first sentence (f) GDPR. We have a legitimate interest in the analysis of user behaviour in order to improve both our web service and our advertising.
On this Website, we have activated the IP anonymisation function. This means that your IP address will, within member states of the European Union or in other states which are party to the Agreement on the European Economic Area, be anonymised by Google prior to being transmitted to the USA. The full IP address will only be transmitted to a Google server in the USA in exceptional cases and anonymised there. Google will use this information, on behalf of the operator of this Website, to evaluate your use of the Website, to compile reports on Website activity and to provide further services to the website operator connected with the Website and internet use. The IP address transmitted by your browser in the scope of Google Analytics will not be joined with other data from Google.
You can prevent cookies being stored through corresponding settings in your browser software; we would, however, make you aware that in this case you may not be able to use all functions of this Website in full. In addition, you can prevent Google from collecting and processing the data (including your IP address) generated by the cookie related to your use of the Website, as well as the processing of such data by Google by downloading and installing the browser add-on available at this link: https://tools.google.com/dlpage/gaoptout.
LinkedIn Insight Tag
You can also prevent LinkedIn from collecting the information generated by the cookie and related to your use of the website and LinkedIn from processing that information by setting an opt-out cookie that prevents your information from being collected in the future when you visit this website. To do this, click on this link:
Deactivate LinkedIn Insight tag
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.
Data processing is justified in accordance with Art. 6 Para. 1 lit. f) DS-GVO, as we have a legitimate interest in displaying personalised advertising to you and evaluating the use of our website.
Facebook pixel and custom audience
On this website, due to our legitimate interest pursuant to Art. 6 (1) (1) (f) GDPR, the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used for the analysis, optimisation and economic operation of our online offer. The Facebook pixel allows us to track the actions of users after they have seen or clicked on a Facebook ad. As a result, we can track the effectiveness of Facebook ads for statistical and market research purposes. The tracking itself is carried out via a cookie, not via the Facebook pixel itself. It is also possible to identify visitors to our online offering as a target group ("custom audience") for the display of ads. Accordingly, we use the Facebook pixel to display Facebook ads placed by us only to Facebook users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in the topics or products defined by us). When custom audience is used via the pixel method, a direct connection is established between the user's browser and the Facebook server. Context data (e.g. forwarding URL, browser information and the Facebook user ID) as well as user-defined data are transmitted to Facebook. In addition, we cannot exclude the possibility that other personal user data may be transmitted to and processed by Facebook. Facebook may associate the visit to our website with the corresponding Facebook account and identify the user accordingly. For us, the data collected is anonymous, i.e. we do not see the personal data of individual users.
Facebook may also use this information for its own promotional purposes in accordance with Facebook's Data Protection Policy. You may enable Facebook and its affiliates to serve advertisements on and off Facebook. A cookie may also be stored on your computer for these purposes.
We use the Unbounce service for individual subpages. The provider is Unbounce Marketing Solutions Inc. 400-401 West Georgia Street, Vancouver, BC, Canada, V6B 5A1.
The EU Commission has classified Canada as a secure third country, with an adequate level of data protection, and we have entered into a contract processing agreement.
Individual subsites are hosted by Unbounce and your browser communicates directly with Unbounce so that your IP address is transmitted and cookies can be set. All information you enter on these pages is also stored by Unbounce. We are then provided with an anonymous evaluation of the activities.
Further information on Unbounce and data protection at Unbounce can be found here: https://unbounce.com/privacy/
Our website uses features of the marketing automation service Autopilot HQ. Provider is Autopilot Inc., 717 California Street, Level 1, San Francisco, CA, 94108, USA. AutopilotHQ uses so-called "cookies". These are text files which are stored on your computer and which allow an analysis of your use of the website. The information generated by the cookie about your use of this website will generally be transmitted to and stored by Autopilot on servers in the United States.
Further information on data protection can be found in the Autopilot data protection declaration at https://autopilothq.com/privacypolicy.html
Recipients of data
Some of your personal data may be disclosed to certain recipients for the aforementioned purposes. Such recipients include, for example, contractors who support us in the provision of our services. One of these would be DigitalOcean LLC., 101 Avenue of the Americas, 10th Floor, New York, NY 10013, USA, a hosting provider which provides our webspace. The personal data is stored in a database of ObjectLabs Corporation, 660 York Street, Suite 101, San Francisco, CA 94110, USA. We conclude data processing agreements with such contractors to ensure they process your personal data strictly in accordance with our instructions and to the extent permitted by law. The legal basis for the transfer of data is Art. 28 GDPR in conjunction with this agreement.
To the extent that we are legal obliged to disclose personal data (e.g. to public authorities), the legal basis is Art. 6 (1) first sentence (c) GDPR.
In addition, personal data may in certain cases be disclosed to attorneys and the courts. This transfer of data is based on Article 6 (1) first sentence (f) GDPR. We have a legitimate interest in asserting our own claims and defending ourselves against third party claims.
A transfer of data to recipients outside the European Economic Area will not occur.
Automated decision making
We do not process your personal data for the purpose of any automated decision-making which could have a legal effect on you or significantly affect you in a similar manner.
Period of storage
Rights of the Data Subject
You have the following rights, depending on the circumstances of the specific case:
• The right to obtain access to your personal data and/or copies of that data. This includes information regarding the purpose of the use, the category of personal data used, the recipients of the data and persons authorised to access the data, as well as, where possible, the envisaged period for which the data will be stored or, if not possible, the criteria used to determine that period;
• The right to request rectification or erasure of personal data or the restriction of processing of personal data, to the extent that its use is not permitted under data protection law, including where (i) the data is incomplete or inaccurate, (ii) the data is no longer required for the purpose for which it was collected, (iii) the consent on which the processing is based has been revoked, or (iv) you have successfully exercised your right to object to the processing of data; in cases in which the data is processed by third parties, we will forward your requests for rectification, erasure or restriction of processing to those third parties, unless this proves impossible or involves unreasonable effort;
• The right to obtain the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller without hindrance from us; you also have the right to have us transmit the personal data directly to another controller, where this is technically possible;
• The right to refuse consent to the processing of data or to withdraw a consent previously granted at any time without giving reasons and with effect from that point forward;
• The right to lodge a complaint with the competent supervisory authority or the supervisory authority in the Member State in which you have your residence or place of work, if you believe that the processing of your personal data breaches any data protection provisions.
Right to Object
If the processing of your personal data is carried out for the purposes of direct marketing, for our legitimate interests (Art. 6 (1) first sentence (f) GDPR) or for the performance of a task carried out in the public interest or in the exercise of official authority (Art. 6 (1) first sentence (e) GDPR), you have the right to object at any time, for reasons which arise from your particular situation.
Last updated on: 25 March 2019