For what purposes do we process your data?

Whenever you visit our homepage, your browser will contact our web server to find the page you wish to visit. In this context, your browser will transmit personal data to us, such as your IP address (i. e. HTTP/S requests). The connection data will be processed by our web server to enable you to access and display our homepage.

Our web server will automatically store a log of the web pages you visit (the so-called “log files” or “session logs”). We use these log files to ensure the security of our homepage, in particular to prevent unauthorised intrusions into our homepage, and to help us exercise our legal rights and obligations to deflect such unauthorised intrusions.

We will also analyse the session logs to optimise our homepage. The evaluation as such takes place in anonymous form, so that the results do not permit any conclusions regarding your person.

The following personal data will generally be processed in conjunction with your visit of our homepage:

• your IP address,

• date and time of your query,

• content of the request,

• access status/HTTP status code,

• scope of the data transfer,

• the website from which your query is forwarded,

• browser type, operating system and its interface, language and the browser software version,

• the place from where you retrieve data from our homepage, and

• other connection data and sources that you are retrieving.

On what legal grounds do we process your data?

The legal basis for processing your data while you browse our homepage always depends on the purpose of your visit. If you visit our homepage to obtain information about our offers, especially if you contact us for the same reason, the legal basis for doing so is Art. 6, Sec. 1, Lit. b, GDPR (initiation of a contract). If you visit our homepage for general information purposes or otherwise, the legal basis is our legitimate interest in operating a website for general information and communication purposes and for the presentation of our company, as well as your legitimate interest to view it (Art. 6, Sec. 1, Lit. f, GDPR). The log files are processed on the basis of our legitimate interests as defined in Art. 6, Sec. 1, Lit. f, GDPR. Our legitimate interest is to protect our facilities and systems from attack and to take legal action against attackers if necessary, as well as to keep developing our websites for commercial purposes.

Who will your data be shared with, and who is involved in the processing of your data?

Our IT department has access to the log files, and will share them with certain internal and external recipients, including competent authorities, whenever doing so is necessary to exercise our legal rights regarding unauthorised intrusions into our homepage. In addition, we have contracted service providers who are involved in the provision of our homepage, and who act on our behalf (Art. 28, GDPR).

Our website is operated via servers of Vercel Inc. (548 Market St. #61948, San Francisco, CA 94104, USA), which acts as a service provider for hosting services on our behalf (Art. 28 DSGVO).

Our website also uses the unbounce service for individual subpages (in particular landing pages). The provider is Unbounce Marketing Solutions, Inc., 400-401 West Georgia Street, Vancouver, BC V6B 5A1, Canada.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

How long will your data be stored?

Your personal data are deleted after 30 days.

Are you obliged to provide your data, and what happens if you prefer not to?

You will not be able to view our homepage unless you let us process the personal data detailed above.

Who is the controller responsible for the Google Maps service?

Our homepage uses the Google Maps service, e. g. to pinpoint the location of each of our properties.

Accountable for the service under data protection law is the company Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland). We have no way to access the data collected by Google within the framework of its map service. Any processing of these data is solely controlled by Google. For more details, check Google’s own data protection policy (available at policies.google.com/privacy).

For what purposes does the homepage use the Google Maps service?

We mark the locations of our properties in Google Maps and embed these maps on our homepage to enable visitors to quickly find the respective locations, and to make our homepage more attractive.

On what legal grounds do we process your data?

From Accentro’s perspective, the processing of your personal data in connection with the Google Maps service serves legitimate interests pursuant to Art. 6, Sec. 1, Lit. f, GDPR. Our legitimate interest consists in efforts to optimise our homepage to further our business purposes and to enable visitors to quickly find the locations of our properties on offer. For more information on the legal basis for the processing of your personal data, please refer to the privacy policy of Google in its role as controller of the service (available at policies.google.com/privacy).

Who will your data be shared with, and who is involved in the processing of your data?

We do not have access to your personal data in the context of the Google Maps service and share no information with third parties. For more information about how Google in its role as controller shares your personal data, please see Google’s own privacy policy (available at policies.google.com/privacy).

Are your data transferred to a third country or to an international organisation?

We do not transfer your personal data to any third country or any international organisation in connection with the Google Maps service. If the Google Maps service connects to servers of Google as the controller of that service, and personal data is transmitted by you for this purpose, you will find further information on relevant aspects in Google’s own privacy policy (available at policies.google.com/privacy).

How long will your data be stored?

We store no personal data in connection with the Google Maps service. For more information about how Google in its role as controller stores your personal data, please see Google’s own privacy policy (available at policies.google.com/privacy).

Are you obliged to provide your personal data, and what happens if you prefer not to?

You are not obliged to provide us with the personal data specified above. However, it is impossible to display the maps embedded on our homepage without processing your personal data.

What are cookies in this context?

In the context of the Internet, the term “cookie” normally refers to a small text file that is stored in the browser directory of your computer or in sub-folders whenever you visit websites, in the case of our homepage meaning either for the duration of your visit or against your next visit in future. Cookies allow our homepage to retrieve or store information about you, about your settings or about your device from your browser. They are mainly used to ensure that the features of our homepage function as expected. As a rule, cookies contain no information that could be used to identify you directly. Yet they make it possible for us to bring you a personalised web experience.

What types of cookies and other technologies does our homepage use?

We use various types of cookies and other technologies on our homepage. We distinguish between the following categories and types of data processing associated with them:

• essential

• performance

• marketing

What are “essential cookies”?

Essential cookies are necessary to make a given website work by enabling basic functions such as page navigation and access to secure areas of that website. Without cookies of this type, a website would not run properly.

For what purposes do we employ essential cookies?

We use essential cookies that are necessary to enable users to visit our homepage. They are normally placed only when you take an action to request certain services, e. g. by filling out one or several of our forms. No services that you may request can be performed without these essential cookies. The cookies help us to process essential cookie data, for example your unique session ID, authentication data and the time of your login (the so-called time stamp). The data allow us to link a given visitor’s unique session to data on our server. The cookies serve as reference for the session created. Whenever an operation is performed on our homepage, our server will recognise your session ID and validate the operation.

On what legal grounds do we process your data?

The legal basis for placing essential cookies, accessing the data stored in them and processing the personal data associated with them is Art. 6, Sec. 1, Lit. f, GDPR. In the latter case, the processing of essential cookie data serves our legitimate interest to enable our users to visit our homepage, and to help us further our business.

Who will your data be shared with, and who is involved in the processing of your data?

The essential cookies are processed by our servers and our IT service provider as our commissioned data processor. Additional commissioned data processors may become involved on a case-to-case basis.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

Are you obliged to provide your personal data, and what happens if you prefer not to?

Disabling essential cookies will compromise the performance of our homepage. For instance, some functions and features of the homepage may not be available to you after disabling them.

What are performance cookies/technologies?

Performance cookies/technologies enable us to provide improved functionality and to simplify use (e. g. by remembering your login details, speeding up the display of our homepage via load balancing).

For what purposes do we employ performance cookies/technologies?

Cookies and technologies of these categories are currently used to improve the usability and appearance of our homepage.

On what legal grounds do we process your data?

We use cookies/technologies requiring consent only if and insofar as you previously consented to it via our cookie consent banner. The legal basis for the use of consent-based cookies is Art. 6, Sec. 1, Lit. a, GDPR.

You may revoke your consent any time using the following link: Change settings

Who will your data be shared with, and who is involved in the processing of your data?

The essential cookies/technologies are processed by our servers and our IT service provider as our commissioned data processor. Moreover, we may involve additional commissioned data processors on a case-to-case basis.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

Are you obliged to provide your personal data, and what happens if you prefer not to?

We use marketing cookies/technologies only if you previously consented to their use via our cookie consent banner.

Use of our homepage is possible even without the use of marketing cookies/technologies. You are under no obligation to grant your consent to their use.

Moreover, you may revoke your consent to the use of consent-based cookies any time with effect to the future by adjusting your cookie settings here: Change settings

What are marketing cookies/technologies?

Marketing cookies/technologies help to track the use pattern of visitors to our homepage in order to display relevant and engaging advertisements to them.

For what purposes do we employ marketing cookies/technologies?

We use marketing cookies/technologies to follow visitors on websites. The idea is to select and display ads that are relevant and appealing to a given user, and that are consequently more valuable to publishers and third-party advertisers. These technologies help us process data on use patterns, e. g. your user settings and statistical data on visitors’ interaction with the homepage.

On what legal grounds do we process your data?

We use cookies/technologies requiring consent only if and insofar as you previously consented to it via our cookie consent banner. The legal basis for the use of cookies/technologies requiring consent is Art. 6, Sec. 1, Lit. a, GDPR.

You may revoke your consent any time using the following link: Change settings

Who will your data be shared with, and who is involved in the processing of your data?

The marketing cookies/technologies are processed by our servers and our IT service provider as our commissioned data processor. Moreover, we may involve additional commissioned data processors on a case-to-case basis.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

Are you obliged to provide your personal data, and what happens if you prefer not to?

We use marketing cookies/technologies only if you previously consented to their use via our cookie consent banner.

Use of our homepage is possible even without the use of marketing cookies/technologies. You are under no obligation to grant your consent to their use.

Moreover, you may revoke your consent to the use of consent-based cookies/technologies any time with effect to the future by adjusting your cookie settings here: Change settings

Who is the controller responsible for data processing whenever social media plug-ins are used?

We process no personal data in connection with your use of social media plug-ins on our homepage. Neither do we have access to the data collected by any social media plug-in and transmitted to the respective social media provider. This means any data processing in this context is done exclusively by the respective social media provider. We use the following social media plug-ins:

• Facebook (provider: Facebook Ireland, 4 Grand Canal Square, Dublin 2, Ireland)

• Instagram (provider: Facebook Ireland, 4 Grand Canal Square, Dublin 2, Ireland)

• YouTube (provider: Google Ireland Limited, Google Building Gordon House, Barrow Street, Dublin 4, Ireland)

• Twitter (provider: Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA)

• Xing (New Work SE, Dammtorstrasse 30, 20354 Hamburg, Germany)

• LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA)

That being said, we would still like to inform you about the processing of your personal data in this context to ensure optimal transparency. For more details regarding the processing of personal data, please contact the respective social media provider or check the respective provider’s privacy policy:

• Facebook & Instagram: https://www.facebook.com/policy.php

• YouTube: https://policies.google.com/privacy?hl=en

• Twitter: https://twitter.com/en/privacy

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

• LinkedIn: https://www.linkedin.com/legal/privacy-policy

For what purposes are social media plug-ins employed?

To enhance your user experience, our homepage contains social media plug-ins that permit the direct posting of links and content of our homepage on the respective network.

In this context, we use the so-called two-click solution. This means that, in principle, visiting our homepage will initially not cause your personal data to be passed on to the providers of any social media plug-in (as detailed above). You can recognise the provider of the plug-in by the marked box above its initial letter or by its logo. We offer you the option to communicate directly with the provider of the plug-in via the button. Only if you click on the marked box, thereby enabling it, will the relevant social media providers collect and process information about your visit to our homepage for their own business purposes. This kind of processing is neither initiated nor controlled by us.

For more details regarding the processing of personal data, please contact the respective social media provider (see details above) or examine the respective provider’s privacy policy (see details above).

On what legal grounds do we process your data?

The processing of personal data by us in this context (whenever it does take place) is based on our legitimate interests: (i) to increase the attractiveness of our homepage and with it the number of visitors and (ii) to increase the visibility of our content and thereby to boost the public image of our company (Art. 6, Sec. 1, Lit. f, GDPR).

For details regarding the legal basis for the processing of personal data by a given social media provider, please contact the respective social media provider or examine the respective provider’s privacy policy (see details above).

Who will your data be shared with, and who is involved in the processing of your data?

We neither have access to personal data nor do we share any personal data with anyone in this context.

To learn more about the forwarding of personal data by a given social media provider, please contact the respective social media provider directly.

Are your data transferred to a third country or to an international organisation?

We transfer no personal data to any third country in this context. However, the social media plug-in may connect to the web server of that social media network in the United States of America. For details regarding the legal basis for the transmission of personal data and corresponding privacy guarantees, please contact the respective social media provider or check the respective provider’s privacy policy (see details above).

How long will your data be stored?

We store no personal data in this context. For details regarding the storage of personal data by a given social media provider, please contact the respective social media provider or check the respective provider’s privacy policy (see details above).

Are you obliged to provide your personal data, and what happens if you prefer not to?

Without the processing of the aforesaid personal data, you would not be able to use any links or other contents on our homepage.

How is the data processing structured, and who is the controller responsible for the data processing?

We have embedded YouTube videos in our online service that are stored on www.YouTube.com and may also be viewed directly on our homepage. These are embedded in the “extended data protection mode,” which means that no data about you as a user will be transmitted to YouTube unless you view a given video. Only when you click to view a video will your data be transmitted to YouTube. These data transmissions are outside our control. They will happen regardless of whether you have and are logged into a YouTube user account or whether you have no such user account. If you are signed into a Google service, your data will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you should log out before activating the button. YouTube stores the data collected about you in the form of a user profile and uses it for advertising purposes, market research and/or the demand-oriented design of its website. 

Accountable under data protection law is the company Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland). We have no way to access the data collected by Google during the playback of videos. Any processing of these data is solely controlled by Google. For more details, check Google’s own data protection policy (available at policies.google.com/privacy).

For what purposes are YouTube videos embedded in our homepage?

YouTube videos are embedded in order to present our company and our respective offers to visitors of our homepage in the most engaging manner possible.

On what legal grounds do we process your data?

From Accentro’s point of view, the processing of your personal data in connection with the embedded YouTube videos serves legitimate interests pursuant to Art. 6, Sec. 1, Lit. f, GDPR. Our legitimate interest is to optimise our homepage so as to further our business purposes and to provide visitors with varied and appealing options for engaging with our company’s products and services. For more information on the legal basis for the processing of your personal data, please refer to the privacy policy of Google in its role as controller of the service (available at policies.google.com/privacy).

Who will your data be shared with, and who is involved in the processing of your data?

We do not have access to your personal data in the context of embedded YouTube videos, and share no information with third parties. For more information about how Google in its role as controller shares your personal data, please see Google’s own privacy policy (available at policies.google.com/privacy).

Are your data transferred to a third country or to an international organisation?

We do not transfer your personal data to any third country or any international organisation in connection with embedded YouTube videos. For more information about data processing on Google servers and the associated processing of personal data in third countries (e. g. the United States), please refer to Google’s own privacy policy (available at policies.google.com/privacy).

How long will your data be stored?

We store no personal data in connection with embedded YouTube videos. For more information about how Google in its role as controller stores your personal data, please see Google’s own privacy policy (available at policies.google.com/privacy).

Are you obliged to provide your personal data, and what happens if you prefer not to?

You are under no obligation to provide us with the personal data specified above. However, it is impossible to view the YouTube videos embedded on our homepage without processing your personal data.

For what purposes do we process your data?

We operate a blog on our homepage. The blog is used to publish a variety of articles on relevant topics. You may comment on the articles, and any comments you leave will be visible to the public. If you leave a comment, it will be published below the respective article and show the (possibly anonymised) user name you provided. Your comments will not be reviewed prior to publication. We will, however, check random samples, and may decide to delete any comments that could contain unlawful content. In case you leave a comment, we will store your email address because we may be liable for the publication of unlawful content. Doing so gives us a chance to contact you and ask for a clarifying statement if we become aware of possibly infringing content. However, your e-mail address will not be published.

On what legal grounds do we process your data?

Data processing serves our legitimate interest to protect us from claims by third parties for infringing content. Legal basis for the data processing is Art. 6, Sec. 1, Lit. f, GDPR. In one-off cases, data may also be processed to fulfil legal obligations pursuant to Art. 6, Sec. 1, Lit. c, GDPR.

Who will your data be shared with, and who is involved in the processing of your data?

The data are principally passed on to competent in-house departments only. Where required by law, data may also be passed on to competent authorities, e. g. in conjunction with a suspected criminal offence.

Are your data transferred to a third country or to an international organisation?

No, we will not transfer your personal data to a third country or to an international organisation in this context.

How long will your data be stored?

Your data will be deleted once they are no longer required to achieve the purpose for which they were collected, and if there are no retention obligations to observe.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to provide us with the personal data specified above. However, without the processing of the aforesaid data, you will not be able to leave any comment on our blog.

For what purposes do we process your data?

You have the option to register as user of our homepage and to create a personal account. As a registered user, you may save your personal search details, search requests, and notes on individual properties, among other things. As a registered user, you can also earmark specific properties for later visits and have them displayed during a future visit or share them with others. To register, you will have to enter your e-mail address, a password of your choice and your freely definable user name. We will also collect your name, your telephone number and your place of residence. Our registration process uses the so-called double opt-in procedure, i. e. your registration is not complete until you have confirmed your registration by clicking on the link sent to you in the form of a confirmation e-mail. While the aforementioned details represent required data; any additional information such as street, address, postcode and mobile phone number are disclosed at your discretion.

You can also subscribe your saved search requests by e-mail. By ticking the appropriate check box, you agree that we may use your email address to send you regular updates on properties that match your search requests. You may revoke your consent with effect to the future at any time by clicking on the unsubscribe link at the bottom of every e-mail or by sending us a message using the contact details below.

On what legal grounds do we process your data?

Registering for our homepage is voluntary and supports our legitimate interest to ensure the use of our homepage is optimised for your convenience. The legal basis for the data processing is Art. 6, Sec. 1, Sent. 1, Lit. f, GDPR.

The legal basis for processing your data in connection with any search requests you may have stored is Art. 6, Sec. 1, Sent. 1, Lit. a, GDPR (contract initiation, execution of the license agreement).

Who will your data be shared with, and who is involved in the processing of your data?

Your data are processed by the competent in-house department, and will in certain cases be passed on to commissioned data processors.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

How long will your data be stored?

When you register for our homepage, we will store the data necessary for registering until you terminate your user account. You can manage the details of your customer account under https://accentro.de/en/login and change or delete them as needed. Moreover, your data will be deleted once they are no longer required to achieve the purpose for which they were collected.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to provide us with the personal data specified above. However, without the processing of the aforesaid data, you will not be able to set up a customer account and to save any search requests.

For what purposes do we process your data?

You have the option to subscribe our free newsletter, which briefs you on our latest listings and other developments.

You can subscribe our newsletter on our homepage. When you register for the newsletter, the following details will be transmitted to us:

• your e-mail address,

• date and time of your registration,

• your IP address,

• date and time at which you clicked the confirmation link,

• optional details you may have provided.

Within the framework of registering, we will ask you to consent to the processing of your data. Moreover, we use the so-called double-opt procedure. This means that, in response to your registration, we will send you an e-mail to the e-mail address your submitted that will ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, any details you provided will automatically be deleted.

If you purchase any goods or services from us and submit your e-mail address in this context, we may subsequently use it to send you our newsletter. In such a case, the newsletter will only be used to send you direct advertising for similar goods or services available from us. You may object to the use of your e-mail address for these purposes.

On what legal grounds do we process your data?

Your data is processed in order to deliver the newsletter to you, and to prevent misuse of the e-mail address used. Legal basis for the data processing is your consent (Art. 6, Sec. 1, Sent. 1, Lit. a, GDPR).

You may revoke your consent—as well as your consent to having e-mails sent to you pursuant to Art. 7, Sec. 2, No. 3, German Act Against Unfair Competition (UWG)—with effect to the future at any time, and unsubscribe our newsletter. To declare your revocation, you may either click on the link provided in each e-mail for this purpose or by sending a note to the contact specified in Section 11, below. The legitimacy of having processed your data up to the time you revoke your consent to it will not be affected by the revocation.

The legal basis for mailing out a newsletter after the sale of goods or services to the buyer is our legitimate interest in marketing our offerings and approaching potentially interested customers (Art. 6, Sec. 1, Sent. 1, Lit. f, GDPR i. c. w. Art. 7, Sec. 3, UWG).

Who will your data be shared with, and who is involved in the processing of your data?

The data are processed by the competent in-house department, and are in certain cases passed on to commissioned data processors.

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

How long will your data be stored?

The data are normally deleted as soon as they cease to be required to achieve the purpose for which they were collected and upon expiration of any additional statutory retention periods (e. g. up to 10 years according to the German Commercial Code [HGB] or the Fiscal Code of Germany [AO]). Accordingly, the e-mail address of a given user will only be saved as long as that user’s newsletter subscription remains active.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to provide the data specified above to us. However, without the processing of the aforesaid personal data, you will not be able to receive our newsletter.

For what purposes do we process your data?

Our app lets you hunt for interesting ownership apartments among our listed properties, tag properties, contact the adviser responsible for a given property, share sell sheets, and keep notes on properties that you are interested in.

You have the option to register as user of our app and to create a personal account. As a registered user, you may save your personal search details, search requests, and notes on individual objects, among other things. As a registered user, you can also earmark specific properties for later visits, and have them displayed during a future visit, or share them with others. To register, you will have to enter your e-mail address, a password of your choice and your freely definable user name. We will also collect your name, your telephone number and your place of residence. Moreover, you may volunteer additional details (e. g. street, address, mobile phone number). Our registration process uses the so-called double opt-in procedure, i. e. your registration is not complete until you have confirmed your registration by clicking on the link sent to you in the form of a confirmation e-mail.

You can also subscribe e-mail updates on your saved search requests. You may revoke the consent you thereby granted at any time with effect to the future by clicking on the unsubscribe link at the bottom of every e-mail or by sending us a message using the contact details (see Section 11, below).

On what legal grounds do we process your data?

Processing of data in conjunction with your property search and your registration is done on the legal basis of Art. 6, Sec. 1, Sent. 1, Lit. b, GDPR (contract initiation, execution of the license agreement).

On top of that, processing your data serves our legitimate interest to make your property search more convenient and to present our company in an engaging manner. The legal basis for the data processing is Art. 6, Sec. 1, Sent. 1, Lit. f, GDPR.

Who is involved in the processing of your data?

In principle, your data are processed fully automatically by the application and the servers we use.

Are your data transferred to a third country or to an international organisation?

No, your data will not be transmitted to any third country or to any international organisation.

How long will your data be stored?

As a rule, we will save the data you provide when registering for our app until you delete your user account. You can manage your data in your customer account, and change or delete them as needed. In addition, your data will be deleted as soon as they cease to be required to achieve the purpose for which they were collected and upon expiration of any possibly existing statutory retention periods (e. g. up to 10 years according to the German Commercial Code [HGB] or the Fiscal Code of Germany [AO]).

Are you obliged to provide your data, and what happens if you prefer not to?

Both your use of the app and the creation of a customer account is voluntary, as is, for example, the saving of search requests. However, use of the various features will be impossible without processing of your personal data.

Who is the controller responsible for the data processing?

We maintain presences on social media and other platforms (e. g. LinkedIn, XING, Immobilienscout24). The respective platform provider is primarily responsible for data processing in this context under data protection law. For details on this kind of data processing, please check the privacy policies of the respective platform providers.

Accentro (together with a given social media provider, if any), is accountable under data protection law for data processing in the following instances:

• running statistical analysis of the use patterns of visitors. However, these data are normally available to us in anonymised form only.

• interacting with our social media team and responses to our posts (e. g. in the form of comments, likes, etc.).

For what purposes are data being processed?

When you visit any of our presences—regardless of whether or not you are logged in—the respective platform provider collects personal user data (usage data), some of which will be shared with us in the form of user statistics. But we do not have full access to the data collected or to your profile data.

For example, the following data may be made available to us in anonymised form:

• followers/fans, etc. the trend in the number of people who follow our sites.

• reach: e. g. the number of people seeing a specific contribution.

• the ad performance (where relevant): How many people have seen a given ad?

• demographics: the average age of the visitors, gender, place of residence, language.

However, the usage data permit no conclusions about individual users. Statistics are used only to enhance the online service of our presences and to be more responsive to interests shown by users.

If you interact with us via our presences on social media or other platforms, e. g. by commenting on posts or sending us messages, the related contents of the interaction will be processed by us. In addition, we can see the public information that you provide in your profile, if any, and that you can keep managing on your own.

On what legal grounds do we process your data?

Insofar as we process your usage data, we believe that this serves legitimate interests pursuant to Art. 6, Sec. 1, Lit. f, GDPR. Our legitimate interest is to optimise the user experience on our homepage and strengthen our presence on social networks so as to further our business purposes. This will improve our customer service, ensure effective information updates to our users and timely communication, and promote our business purposes through advertising opportunities, among other things.

If you communicate directly with us via our social media presences, the legal basis for processing your data depends on the specific purpose of the exchange. Art. 6, Sec. 1, Lit. b, GDPR, will apply if the exchange is connected with the initiation or fulfilment of a contract with you. Otherwise, Art. 6, Sec. 1, Lit. f, GDPR (our legitimate interest to engage in business correspondence or to reply to inquiries regarding data protection, for example) tends to apply.

Who will your data be shared with, and who is involved in the processing of your data?

Your data will only be used or forwarded internally by the persons in charge of a given process. For details on who is involved in the processing of data at the respective platform provider, please check the privacy policy of the respective platform provider.

Are your data transferred to a third country or to an international organisation?

We do not transfer your personal data to any third country or any international organisation in the context of our social media presence and our presence on other platforms.

There is a chance that a platform provider will connect to servers in third countries (e. g. the United States) as part of its services, and transmit your personal data to that third country. For more information on this subject, please check the privacy policy of the respective platform provider.

How long will your data be stored?

In connection with our presences on social media and other platforms, we principally store no personal data on the servers we use, except in the above-mentioned cases in which we process your information internally (in particular in the context of direct communication). In these cases, the data are normally deleted once they are no longer required to handle your request and upon expiration of any additional statutory retention periods (e. g. up to 10 years in accordance with the German Commercial Code [HGB] or the German Fiscal Code [AO]).

Moreover, we normally have no way to access the data saved by the respective platform. For more details on the storage of your personal data from the platform provider itself, please check the privacy policy of the respective platform provider.

Are you obliged to provide your personal data, and what happens if you prefer not to?

You are under no obligation to make your personal data available. However, visiting our presences on social media or other platforms will either be impossible or restricted without the processing of your personal data.

For what purposes do we process your data?

From time to time, we will provide the opportunity to participate in sweepstakes.

You may use the link […] to register for our sweepstakes. In conjunction with your participation in any of our sweepstakes, we will process the following data:

• your name

• your postal address

• your e-mail address.

On what legal grounds do we process your data?

To the extent required to set up, execute and wrap up the sweepstakes, your data will be processed on the legal basis of Art. 6, Sec. 1, Sent. 1, Lit. b, GDPR.

Any further processing will be subject to your prior consent (Art. 6, Sec. 1, Sent. 1, Lit. a, GDPR). You may revoke your consent with effect to the future any time. To declare your revocation, you may send a note to the contact specified in Section 11, below. The legitimacy of having processed your data up to the time you revoke your consent to it will not be affected by the revocation.

Who will your data be shared with, and who is involved in the processing of your data?

Your data are passed on to the competent in-house department.

Are your data transferred to a third country or to an international organisation?

No, we will not transfer your personal data to a third country or to an international organisation in this context.

How long will your data be stored?

The data are normally deleted as soon as they cease to be required to achieve the purpose for which they were collected and upon expiration of any additional statutory retention periods (e. g. up to 10 years according to the German Commercial Code [HGB] or the Fiscal Code of Germany [AO]). As a rule, the names and contact details of the participants will therefore be deleted after the end of the sweepstakes.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to provide the data specified above to us. However, without the processing of the aforesaid personal data you will not be able to take part in our sweepstakes.

For what purposes do we process your data?

You have the option to contact us, e. g. via e-mail or via the contact form on our homepage, and to submit questions, suggestions or notes to us as well as to request advertising material and information material. In this context, we will process your personal data that are required for communicating with you (the “communication data”), e. g. name, address, e-mail, telephone number as well as the contents of the communication.

Any first contact by you necessitates the processing of your communication data, not least in order to enable us to respond to your query or to reply with clarifying queries of our own.

On what legal grounds do we process your data?

Your communication data are processed on the legal basis of Art. 6, Sec. 1, Lit. b, GDPR, if the exchange is connected with the initiation or fulfilment of a contract with you. Other than that, the legal basis depends on the specific purpose of the exchange. In most cases, Art. 6, Sec. 1, Lit. f, GDPR (our legitimate interest to engage in business correspondence or to communicate with customers or to reply to inquiries regarding data protection, for example) will apply.

Who will your data be shared with, and who is involved in the processing of your data?

The communication data are processed by the competent in-house department, and are not passed on.

Are your data transferred to a third country or to an international organisation?

No, your data will not be transmitted to any third country or to any international organisation.

How long will your data be stored?

Your personal data will be deleted once they are no longer required to handle the communication with you. The data may be stored for an extended period of time on the basis of Art. 6, Sec. 1, Lit. c, GDPR, i. c. w. the relevant statutory retention periods (in particular under commercial, tax and fiscal law). In the case for business correspondence, this tends to be the case six years after the end of the year in which the correspondence took place.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to disclose your personal data to us. However, we will need the relevant data to be able to contact you and to reply to your inquiry.

For what purposes do we process your data?

Our homepage gives you the option to request information about, and quotes for, our properties as well as information on financing options. When you request a quote, the information you enter in the input mask and your IP address are transmitted to us. Out of the data you may enter, only your e-mail address represents a required disclosure. Any other details you care to provide will solely be used by us to address you in person and to compile a personalised quote for you.

Our request-for-information and priority notice processes use the so-called double-opt procedure. This means that, in response to your request, we will send you an e-mail to the e-mail address your submitted that will ask you to confirm that you wish to receive the quote.

On what legal grounds do we process your data?

Your data is processed only to the extent necessary to transmit any quotes you requested or to accept priority notices. The legal basis for the data processing is Art. 6, Sec. 1, Sent. 1, Lit. b, GDPR (contract initiation).

If you have granted your consent, we will use the contact data you provided to notify you about other properties matching your criteria and to send you relevant quotes. You may revoke the consent you granted at any time with effect to the future by sending us a message using the contact details listed below (see Section 11). Legal basis for the data processing is Art. 6, Sec. 1, Lit. a, GDPR.

Who will your data be shared with, and who is involved in the processing of your data?

The data are processed by the competent in-house department, and will not be passed on.

Are your data transferred to a third country or to an international organisation?

No, your data will not be transmitted to any third country or to any international organisation.

How long will your data be stored?

In these cases, the data are normally deleted once they are no longer required to handle your request for information and upon expiration of any additional statutory retention periods (e. g. up to 10 years in accordance with the German Commercial Code [HGB] or the German Fiscal Code [AO]). If you fail to confirm your request for information within 24 hours, any details you provided will be deleted immediately.

Are you obliged to provide your data, and what happens if you prefer not to?

You are under no obligation to disclose your personal data to us. But without access to your data, we have no way to process your request or priority notice, nor will we be able to notify you of future offers.

For what purposes do we process your data?

If you submit a job application, we will process specifically the applicant data you communicated to us, such as e. g.:

• master data and contact details,

• vocations training, professional skills, certificates,

• other data from the application form (esp. notice periods, salary expectation),

• nationality, work permit, and/or

• previous employers.

We will use and store your applicant data for the purpose of initiating an employment relationship, in particular for:

• assessing and screening candidates,

• preparing and conducting personal job interviews over the phone,

• evaluating and assessing the outcome of such interviews,

• contacting candidates for the purpose of making job offers, rejecting applications or submitting open questions that remain,

• considering your profile for open positions that you did not expressly apply for, and/or

• satisfying other needs in conjunction with the headhunting process, and

• setting up the employment relationship, where applicable.

Prior to hiring, we may run certain checks on a case-to-case basis. In the process, we may request information from your previous employers or other relevant contact points within the framework of relevant labour law requirements.

In addition, we will process your data in order to meet legal obligations that require the processing and sometimes even the disclosure of your data. These include, in particular, retention obligations (especially under social security, commercial and tax law) and reporting obligations.

We will also process your personal data in certain one-off cases to protect our legitimate interest in defending ourselves against asserted legal claims (e. g. under the German General Equal Treatment Act [AGG]).

After the conclusion of an unsuccessful application process, we will retain your applicant data in our talent pool, if you so wish, in order to contact you again and, if necessary, process the data further. Doing so will give us the chance to contact you again in the future with suitable job postings that match your profile, and to invite you to other events that may eventually lead to the initiation of an employment relationship.

On what legal grounds do we process your data?

The legal basis for processing personal data while initiating an employment relationship is Art. 26, Sec. 1, Sent. 1, BDSG.

The legal basis for the processing of your application data to meet relevant legal obligations is Art. 6, Sec. 1, Lit. c, GDPR, i. c. w. specific legal facts (e. g. social data protection, retention obligations pursuant to Art. 257, HGB, and Art. 147, AO).

Processing data on the basis of our legitimate interest to defend ourselves against asserted legal claims is done on the legal grounds of Art. 6, Sec. 1, Lit. f, GDPR.

Processing your data in our talent pool is done on the basis of your consent (Art. 6, Sec. 1, Lit. a, GDPR). You may revoke the consent you granted at any time with effect to the future by sending us a message using the contact details below (see Section 11).

Who will your data be shared with, and who is involved in the processing of your data?

Within our company, we will forward your data to the in-house unit handling your application.

Your applicant data will also be processed via the TalentLink application system by Lumesse GmbH, Flughafenstrasse 103, D-40474 Düsseldorf, as commissioned by us. Other than that, we will transfer your personal data to other recipients only if we are under a statutory reporting obligation, e. g. vis-à-vis the authorities.

Are your data transferred to a third country or to an international organisation?

We will not transfer your personal data to a third country or to an international organisation in this context.

How long will your data be stored?

Your applicant data will be stored for as long as it takes to consider your application. If your application is not accepted or if you withdraw your application, your applicant data will be fully deleted 6 months after the despatch of our rejection letter, unless their extended retention is permitted or required on another legal basis (e. g. to exercise our statutory rights or to comply with applicable law). 

In case you are hired, the data will be passed on to the human resources administration system and processed there as employee data. For more details, see our Data Protection Policy for employees. 

If you have granted your consent to be added to the talent pool, we will delete your data immediately after you revoke your consent. Otherwise, your data will be deleted after 6 months at the latest.

Are you obliged to provide your data, and what happens if you prefer not to?

You will necessarily have to make your data available to conclude a possible agreement with us. That said, you are under no statutory or contractual obligation to transmit your data to us. However, since we need information about you to move forward with our hiring process, your failure to make such information available to us may cause you to be overlooked as an applicant.

Withholding your consent to the addition of your applicant data to our talent pool will result in no disadvantages for you during future application processes.

Who is the controller responsible for processing your data?

Joint controller responsible for collecting your personal data during an acquisition process are ACCENTRO GmbH, ACCENTRO Real Estate AG and the respective property vehicle from the Accentro Group who owns the respective property (Art. 26, GDPR).

The information on joint controllership pursuant to Art. 26, Sec. 2, Sent. 2, GDPR, is available under the following link: https://gdpr-info.eu/art-26-gdpr/

For what purposes do we process your data?

Your data are processed, on the one hand, for the purpose of initiating a contractual relationship with you or for the purpose of enabling us to meet our contractual obligations to you.

On the other hand, your data are processed in order to meet legal obligations that require the processing and sometimes the disclosure of your data. These obligations include particularly record-keeping obligations (esp. under commercial and fiscal law), obligations to provide information to supervisory authorities and law enforcement agencies, as well as control and reporting obligations under tax law.

To the extent necessary, your data will be processed over and above the actual fulfilment of the contract for the purpose of serving legitimate interests. Examples for such cases include:

• the assertion of legal claims and the defence in legal disputes,

• processing within the CRM system,

• accounting purposes,

• for settlement purposes within the framework of the collaboration with third-party estate agents.

On what legal grounds do we process your data?

The legal basis for processing your data to initiate a contractual relationship and to meet our contractual obligations is Art. 6, Sec. 1, Lit. b, GDPR.

Data processing to fulfil statutory obligations is based on Art. 6, Sec. 1, Lit. c, GDPR.

In addition, data are processed on the grounds of Art. 6, Sec. 1, Lit. f, GDPR (legitimate interest). Our legitimate interest is, e. g., to defend ourselves in the context of legal disputes, to assert claims in our own right, or to maintain our customer relationships.

Who will your data be shared with, and who is involved in the processing of your data?

We employ commissioned data processors (e. g. IT service providers) to provide our services. Other recipients of personal data could in particular include:

• government authorities and institutions (e. g. inland revenue and law enforcement agencies) assuming the existence of relevant legal or official obligations,

• lenders and financial services providers (in conjunction with payment transactions),

• tax consultants, chartered accountants, payroll auditors and tax auditors (statutory audit mandate),

• third-party estate agents (execution of projects and settlement of commissions), and

• collaboration partners (esp. providers of real estate whose offers we publish)

The disclosure of your data is subject to strict compliance with the GDPR and BDSG requirements.

Are your data transferred to a third country or to an international organisation?

No, your personal data will not be transferred to a third country or to an international organisation.

How long will your data be stored?

Your personal data will be stored only for as long as is necessary to fulfil the purpose for which they were collected. Afterwards, your data will normally be deleted.

However, certain exceptions may apply, specifically:

• if statutory retention obligations (esp. those under commercial and tax law) have to be met. The storage or documentation periods set therein generally tend to range from six to ten years;

• to preserve evidence within the framework of laws governing the statute of limitations. Limitation periods can be as long as 30 years, the normal limitation period being 3 years.

Are you obliged to provide your data, and what happens if you prefer not to?

Within the framework of the contractual relationship, you must provide the personal data that are required for the initiation, performance and termination of the contractual relationship and for the fulfilment of the associated contractual obligations or which we are legally obliged to collect. Without these data, we will normally not be able to enter into a contract with you or to fulfil it.

Who is responsible for the use of the DocuSign online signature service in contract processing?

We use the online signature service of the company DocuSign International (EMEA) Ltd, 5 Hanover Quay, Dublin 2, Ireland (hereinafter "DocuSign") in the internal area of the customer accounts to open up the possibility of signing documents online in the purchasing process. ACCENTRO is responsible for data protection. DocuSign is used as part of a commissioned processing and does not process the data independently and in accordance with the terms of the commissioned processing agreement.

For what purposes is the DocuSign service used?

For the conclusion and execution of contracts, a registered customer may resort to signing by means of an electronic signature. When performing the electronic signature with DocuSign the following personal data is processed:

• Identifiers and contact information such as name, postal address and telephone number, e-mail address and passwords

• Device, usage information, and transaction data (e.g., IP address, device information, usage data, subject, and transaction history)

• Commercial information such as billing and payment information (e.g., credit card number, expiration date, visual crypto), products or services purchased

• Geolocation (physical location)

On what legal grounds do we process your data?

The legal basis for processing your data in connection with the use of DocuSign serves, from the point of view of ACCENTRO, the conclusion or execution of a contract pursuant to Art. 6 (1) lit. b DSGVO. A further basis is the legitimate interest from the point of view of ACCENTRO pursuant to Art. 6 para. 1 lit. f DSGVO to be able to offer customers and interested parties the electronic signature of documents online. 

Who will your data be shared with, and who is involved in the processing of your data?

In order for you to be able to carry out the digital signature of the contract documents, it is necessary to pass on the above-mentioned customer data to DocuSign. DocuSign in turn uses its own order processors to carry out the signature. You can view these at the following link: https://www.docusign.com/trust/privacy/subprocessors-list. Other recipients of personal data may also include:

• public bodies and institutions (e.g. financial or law enforcement authorities) if there is a legal or official obligation to do so.,

• credit and financial service providers (processing of payment transactions),

• rax consultants or business and payroll tax and tax auditors (statutory audit mandate),

• external real estate agents (project execution and commission settlements) and

• cooperation partners (esp. providers of real estate who publish their offers through us).

Are your data transferred to a third country or to an international organisation?

Our processor DocuSign processes personal data in third countries (e.g. the United States) on a case-by-case basis. The level of data protection in the USA and other third countries may not correspond to that within the European Union or the scope of the GDPR. However, the protection of your data is ensured in this respect in particular by binding internal data protection regulations within the meaning of Art. 47 DSGVO. You can find further information on the guarantee of data security in the DocuSign company at https://www.docusign.com/privacy/.

How long will your data be stored?

Your personal data will be stored as long as necessary to fulfill the purpose for which it was collected. After that, your data will be deleted on a regular basis. In some cases, exceptions may arise, in particular:

• as far as statutory retention obligations (esp. from commercial and tax law) must be fulfilled. The periods specified there for storage or documentation are generally six to ten years;

• for the preservation of evidence within the framework of the statutory limitation periods. These limitation periods can be up to 30 years, with the regular limitation period being 3 years.

Are you obliged to provide your data, and what happens if you prefer not to?

You are not obliged to provide us with the data mentioned above. However, without processing your data, the conclusion or execution of the contract for a digital signature of documents using DocuSign is not possible.

For what purposes do we process your data?

Whenever you visit our project pages, your browser will contact our web server to find the page you wish to visit. In this context, your browser will transmit personal data to us, such as your IP address (i. e. HTTP/S requests). The connection data will be processed by our web server to enable you to access and display a given project page.

Our web server will automatically store a log of the web pages you visit (the so-called “log files” or “session logs”). We use these log files to ensure the security of our project pages, in particular to prevent unauthorised intrusions into our project pages and to help us exercise our legal rights and obligations to deflect such unauthorised intrusions.

We will also analyse the session logs to optimise our project pages. The evaluation as such takes place in anonymous form, so that the results do not permit any conclusions regarding your person.

The following personal data will generally be processed in conjunction with your visit of our project pages:

• your IP address,

• date and time of your query,

• content of the request,

• access status/HTTP status code,

• scope of the data transfer,

• the website from which your query is forwarded,

• browser type, operating system and its interface, language and the browser software version,

• the place from where you retrieve data from any of our project pages, and

• other connection data and sources that you are retrieving.

On what legal grounds do we process your data?

The legal basis for processing your data while you browse a given project page always depends on the purpose of your visit. If you visit one of our project pages to obtain information about our offers, especially if you contact us for the same reason, the legal basis is Art. 6, Sec. 1, Lit. b, GDPR (initiation of a contract). If you visit the project page for general information purposes or otherwise, the legal basis is our legitimate interest in operating that project page for general information and communication purposes and for the presentation of the respective development project, as well as your legitimate interest to view it (Art. 6, Sec. 1, Lit. f, GDPR). The log files are processed on the basis of our legitimate interests as defined in Art. 6, Sec. 1, Lit. f, GDPR. Our legitimate interest is to protect our facilities and systems from attack and to take legal action against attackers if necessary, as well as to keep developing our project pages for commercial purposes.

Who will your data be shared with, and who is involved in the processing of your data?

Our IT department has access to the log files, and will share them with certain internal and external recipients, including competent authorities, whenever doing so is necessary to exercise our legal rights regarding unauthorised intrusions into our project pages. In addition, we have contracted service providers who are involved in the provision of our project pages, and who act on our behalf (Art. 28, GDPR).

Are your data transferred to a third country or to an international organisation?

Our contracted data processors may process your data inside or outside Germany (e. g. in the United States). However, the safety of your data is ensured, not least by signing standard contractual clauses toward this end.

How long will your data be stored?

Your personal data are deleted after 30 days.

Are you obliged to provide your data, and what happens if you prefer not to?

You will not be able to view our project pages unless you let us process the personal data detailed above.

What are cookies in this context?

Our project pages (e. g. www.riehmers-hofgarten-berlin.de/en) use cookies and other technologies. For a detailed description of cookie functions, please see Section 3.3 of this Data Protection Policy.

What types of cookies and other technology does our homepage use?

We distinguish between the following categories and types of data processing associated with them:

• essential

• marketing