Privacy policy

1. Controller

The controller within the meaning of the General Data Protection Regulation (Datenschutz-Grundverordnung, DSGVO) is:

Email: info@vorsorgedepot-lotse.de

No data protection officer has been appointed, as the statutory requirements for a mandatory appointment (Art. 37 DSGVO, § 38 BDSG) are not met.

2. Overview: what data do we process?

This website (https://www.vorsorgedepot-lotse.de) provides information on the Altersvorsorgedepot (AVD, the new state-subsidised retirement investment account) and state-subsidised private retirement provision. When you visit the website, we process personal data only to the extent technically necessary — specifically:

• technical access data generated when the website is accessed (server logs, section 4),
• the inputs you make in our Förderrechner (subsidy calculator), which are processed exclusively locally in your browser (section 5).

3. Cookies and consent

This website does not use any cookies or comparable technologies that require consent under § 25 para. 1 TDDDG. Only technically necessary mechanisms are used (§ 25 para. 2 no. 2 TDDDG). For this reason, we do not display a cookie banner.

4. Hosting and server log files

This website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA (“Vercel”). When the website is accessed, Vercel automatically processes information on our behalf in what are known as server log files, transmitted by your browser:

• the IP address of the requesting device,
• the date and time of access,
• the page accessed / name of the file retrieved,
• the amount of data transferred and the HTTP status code,
• browser type and version, operating system,
• the referrer URL (the previously visited page).

This processing is based on Art. 6 para. 1 lit. f DSGVO (GDPR). Our legitimate interest lies in the technical provision, stability and security of the website (among other things, defending against attacks). The log data is not combined with other data sources and is automatically deleted after a short period.

We have entered into a data processing agreement (Auftragsverarbeitungsvertrag / Data Processing Addendum) with Vercel pursuant to Art. 28 DSGVO. Vercel is certified under the EU-U.S. Data Privacy Framework; transfers to the USA are therefore covered by the European Commission’s adequacy decision (Art. 45 DSGVO). EU Standard Contractual Clauses (Art. 46 para. 2 lit. c DSGVO) are used in addition. We serve fonts and other static resources ourselves; no fonts or scripts from third-party providers (e.g. Google Fonts) are loaded.

5. Förderrechner

Our website provides a Förderrechner into which you can enter values (e.g. amounts, periods, or comparable information). The calculation is performed locally in your browser; your inputs are not transmitted to our servers. For your convenience, the values you most recently entered may be stored in your browser’s local storage (localStorage) so that they are retained when you visit again. This data remains on your device and can be deleted by you at any time via your browser settings. There is currently no function for sending your results to us.

6. Recipients and transfers to third countries

Within our company, only those departments that need your data to fulfil the purposes described above have access to it. External recipients are exclusively the processors named in this policy (currently Vercel, section 4).

Where service providers process data in the USA, the transfer is based on the adequacy decision for the EU-U.S. Data Privacy Framework (Art. 45 DSGVO) and/or on EU Standard Contractual Clauses (Art. 46 para. 2 lit. c DSGVO).

7. Retention period

We store personal data only for as long as necessary for the purposes stated above or as required by statutory retention obligations (in particular under commercial and tax law, §§ 147 AO, 257 HGB: six or eight years, respectively). The data is deleted thereafter.

8. Your rights

You have the following rights against us with regard to the personal data concerning you:

• Access (Art. 15 DSGVO),
• Rectification (Art. 16 DSGVO),
• Erasure (Art. 17 DSGVO),
• Restriction of processing (Art. 18 DSGVO),
• Data portability (Art. 20 DSGVO),
• Withdrawal of consent given (Art. 7 para. 3 DSGVO), with effect for the future.

Right to object (Art. 21 DSGVO): Where we process data on the basis of Art. 6 para. 1 lit. f DSGVO, you have the right to object at any time to such processing for reasons arising from your particular situation.

An informal message to info@vorsorgedepot-lotse.de is sufficient to exercise your rights.

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 DSGVO), in particular in the member state of your habitual residence, place of work, or the place of the alleged infringement.

9. No automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22 DSGVO takes place.

10. Obligation to provide data

The provision of personal data is neither legally nor contractually required. You can visit our website without actively providing any data; however, without the technical data described in section 4, delivery of the website is not possible.

11. Changes to this privacy policy

We will update this privacy policy if the legal situation or our processing activities change. The version published on this page at any given time shall apply.