Privacy Policy

1. An overview of data protection

General information

Stable Return GmbH (hereinafter referred to as “SR”) is an owner-managed and bank-independent company. Any collection, processing and use (hereinafter referred to as “use”) of data serves exclusively to provide our services. SR provides financial services in the name, on account and under the liability of AHP Capital Management GmbH, Weißfrauenstraße 12-16, 60311 Frankfurt am Main, Germany, hereinafter (“AHP”).

SR always places the highest standards on data protection and data security. SR’s services have therefore been designed with the aim of using as little personal data as possible. The term “personal data” refers to all individual data relating to the personal or factual circumstances of a specific or identifiable natural person or company (so-called “data subject”). The following information on data protection describes the types of data we use to collect from you, the purpose for which this is done and what we do with your data.

The following information provides a simple overview of what happens to your personal information when you visit our website. Personal information is any information that personally identifies you. For detailed information on the subject of data protection, please refer to our data protection declaration listed below this text.

Data collection on our website

Who is responsible for data collection on this website?
The data processing on this website is carried out by the website operator. Their contact data can be found in the imprint of this website.

How do we collect your data?
On the one hand, your data is collected by you communicating it to us. This may involve data that you enter in a contact form, for example.
Other data may be collected automatically by our IT systems when you visit the website. This is mainly technical data (e.g. Internet browser, operating system or time of the page call). This data is collected automatically as soon as you enter our website.

What do we use your data for?
Some of the data is collected to ensure that the website is properly functioning. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?
You have the right at any time and free of charge to receive information about the origin, recipient and purpose of your stored personal data. You also have the right to demand the correction, blocking or deletion of this data. You can contact us at any time at the address given in the imprint for this and other questions on the subject of data protection. Furthermore, you have the right to appeal to the responsible regulatory authority.

2. General information and mandatory information

Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and according to the statutory data protection regulations and this privacy statement. If you use this website, various personal data will be collected.
Personal data is data that identifies you personally. This Privacy Policy explains what information we collect and how we use it. It also explains how and for what purpose this is done. We would like to point out that data transmission over the Internet (e.g. communication by e-mail) can be subject to security risks. A complete protection of the data against access by third parties is not possible.

Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Stable Return GmbH
Christian Frischauf und Alexander Odermann
Weißfrauenstraße 12-16
60311 Frankfurt, Germany
Phone: +49 173 7296749
E-Mail: info@stable-return.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Revocation of your consent to data processing
Many data processing operations are only possible with your expressed consent. You can revoke your consent at any time. For this purpose, an informal e-mail notification to us is sufficient. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

In the event that data are processed on the basis of Art. 6 Sect. 1 lit. e or f GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this Data Protection Declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to Art. 21 Sect. 1 GDPR).

If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21 Sect. 2 GDPR).

Right of complaint to the responsible supervisory authority
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Right to data transferability
You have the right to have data which we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible person, this will only be done as far as it is technically feasible.

SSL and/or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site 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.

Information, blocking, deletion
Within the legal framework, you have the right at any time to receive free information about your stored personal data, its origin and recipient and the purpose of the data processing and, if applicable, the right to correct, block or delete this data.
You can contact us at any time at the address given in the imprint for this and other questions on the subject of personal data.

Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of advertising mails
We hereby object to the use of contact data published within the scope of the imprint obligation to send unsolicited advertising and information material. The operators of this website expressly reserve the right to take legal action against unsolicited mailing or e-mailing of spam and other similar advertising materials.

3. Data collection and use on our website

Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are for example: Browser type and browser version, operating system used, referrer URL, host name of the accessing computer, time of server request, IP address. These data will not be merged with other data sources. The basis for data processing is Art. 6 Sect. 1 lit. f GDPR, which permits the processing of data to fulfil a contract or pre-contractual measures.

Contact form
If you send us enquiries via the contact form, your details from the enquiry form including the contact data you provided there will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. This data will not be passed on without your permission.

The processing of the data entered in the contact form is therefore carried out exclusively on the basis of your consent (Art. 6 Sect. 1 lit. f GDPR). You can revoke this consent at any time. For this purpose, an informal e-mail notification to us is sufficient. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.

The data entered by you in the contact form will remain with us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal requirements – in particular retention periods – remain unaffected.

Use of cookies
On our website, we may use so-called cookies to make visiting our website attractive and to enable the use of certain functions. These are small text files that are stored on your computer and allow an analysis of the use of this website by you. Some of the cookies we use are deleted from your hard drive at the end of the browser session (so-called session cookies). Other cookies remain on your computer and enable us to recognize your computer during your next visit (so-called permanent cookies).

If you do not wish cookies to be used, you can prevent them yourself: The help function in the menu bar of most web browsers explains how to set your browser so that it does not accept new cookies, how to notify you of new cookies or how to delete all cookies that have already been received.

4. Data transmission and transfer

In principle no passing on of personal data
Unless otherwise stated in this Privacy Policy, your personal data will not be disclosed to third parties unless it is legally justified, you have expressly consented to it, or we are required to disclose it, for example, as a result of a court or regulatory order, or to fulfill our contractual obligations to you.

Consent to the transmission of personal data to partners
If you provide us with data via the contact form, SR is entitled to use this data and make it available to partners and their service providers if this is necessary to answer the enquiry.

Consent to the transmission of personal data to cooperation partners and affiliates
SR works with cooperation partners and affiliates to attract investors and financial products advised by SR and to ensure the long-term maintenance of SR’s services. In the event that you are referred to SR by a cooperation partner or affiliate within the scope of this cooperation, you agree that the personal data necessary for the implementation or settlement of this cooperation may be transferred to the respective cooperation partner or affiliate.

Consent to the transfer of data to third-party providers, including from third countries
To enable SR to provide its services, SR also makes use of the support of service providers from third countries. To enable SR to provide its services, you agree that SR may transfer the necessary personal data to the categories of recipients listed below for processing and use in third countries. You are aware that data protection requirements in third countries are lower than in the member states of the European Union. All data mentioned in this data protection declaration, which may also be personal, may be transmitted for the purpose of mediation.

Recipients within the meaning of this declaration of consent are also the named service providers:

  • Service providers whose social plugins or websites are used by SR:
    • LinkedIn (599N Mathilda Ave, Sunnyvale, CA 94085, USA)
    • YouTube, LLC (901 Cherry Ave. San Bruno, CA 94066, USA)
    • XING AG (Gänsemarkt 43 – 20354 Hamburg – Deutschland)
  • Service provider with whose help SR carries out advertising measures and analysis processes using cookies:
  • Social Plugins from Google +, Google Adwords and Google Tag Manager from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)

Other service providers with whose help SR enables users to make use of its services or whose services are necessary for the establishment, implementation or termination of SR’s obligations towards its users. The above declaration of consent is voluntary and can be revoked at any time for the future. If you do not agree with the use and transfer of personal data in third countries, do not contact www.stable-return.de, so that no data transfer or transfer takes place.

Consent to transmission to companies associated with SR
You agree that SR, in the course of its business activities, may disclose your personal data in accordance with this Privacy Policy to companies affiliated with SR, if it is necessary for the establishment, performance or termination of SR’s obligations towards you. This includes in particular AHP Capital Management GmbH.

If you do not agree with the passing on and transmission of your personal data to companies affiliated with SR, do not contact www.stable-return.de, so that no data passing on or transmission takes place.

Embedded Videos
This website may include YouTube plug-ins from YouTube, LLC (901 Cherry Ave. San Bruno, CA 94066 USA) in its information offering. This YouTube software uses cookies for data collection and statistical data evaluation. Among other things, YouTube uses cookies to collect reliable video statistics, to prevent fraud and to improve user friendliness. YouTube cookies provide the website operator with statistical values for calling up individual videos embedded in the website without reference to the respective user.
YouTube’s embedded videos are used by YouTube within the scope of permitted use by YouTube, which all users must accept. If you see any copyright infringement, please report this directly to YouTube. We use embedded YouTube videos in advanced privacy mode. This means that YouTube does not store cookies for a user who displays a website with an embedded YouTube video player but does not click on the video to start playback. When the YouTube video player is clicked, YouTube may be able to store cookies on the user’s computer, but no personal cookie information is stored for embedded video playback. (Source: YouTube “Enable advanced privacy mode for embedded videos”) Please refer to YouTube’s general privacy notice for details. We do not collect personally identifiable information when embedding YouTube videos.

Use of Google Analytics
Google Analytics, a web analytics service provided by Google, is not used.

5. Subject to change 

We reserve the right to change this data protection declaration in compliance with the statutory provisions.

As of: June 2019